The Vigilance Plan includes effective application measures intended to ensure the correct implementation of the Applicable Rules by the Subsidiaries and Suppliers. Monitoring of compliance with the Plan is carried out through audits and analyses performed by external service providers or by Group teams. In addition, the Subsidiaries and Suppliers are asked to carry out self-assessments.
(i) Adoption of Applicable Rules by Subsidiaries
The effective implementation of Applicable Rules by Subsidiaries is achieved through their incorporation in the Group’s Internal Rules. For this purpose, compliance with the effective application of the Plan is based on control activities in accordance with the applicable legislation.
The communication of Applicable Rules to Group employees is described below.
(ii) Adoption of Applicable Rules by Suppliers
Suppliers undertake to comply with the Applicable Rules. In particular, the principal Suppliers sign the Letter of Ethical Commitment that covers these applicable Rules. Moreover, the Suppliers that could present the most significant risks because of their activity or geographic location may be audited on these issues in accordance with the Risk Matrix. The contents of the points that will be audited is set forth in the letter.
L’Oréal’s commitment to Human Rights and Fundamental Freedoms, the health and safety of people in the workplace and the environment 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 each year. These commitments are also set out in the Group’s Code of Ethics and the Human Rights and Employee Human Rights Policy.
The Chief Corporate Responsibility Officer, a member of the Executive Committee, is responsible for overseeing the respect of Human Rights and fundamental freedoms in the Group. This mission has been entrusted to her by L’Oréal’s Chief Executive Officer, to whom she reports.
The Chief Corporate Responsibility Officer has a budget and a dedicated team of Human Rights experts. She relies on all the Group’s teams and resources to carry out her work.
A dedicated network of Human Rights Correspondents covering all of the Group’s markets allows the Group’s commitments in terms of Human Rights to be rolled out.
The Human Rights Committee, chaired by the Chief Corporate Responsibility Officer and composed of representatives of the various activities, functions and geographic areas (including Purchasing, HR, CSR, Safety, Security, etc.), allows coordination and exchange on the implementation of the Group’s Human Rights policy. Its primary objective is to enable the emergence of a Human Rights culture within the Group.
Country Managers (or, for Corporate or Zone staff, the members of the Group’s Executive Committee to whom they report) are responsible for ensuring compliance with Human Rights and fundamental freedoms.
The Human Resources teams are responsible for ensuring that the activities of the Subsidiaries respect employees’ Human Rights and fundamental freedoms.
Employees may contact their manager, their Human Resources Director, their Legal Director, their Purchasing Director, their Human Rights Correspondent, their Ethics Correspondent and, ultimately, the Chief Ethics, Risk and Compliance Officer if they have any questions about compliance with the Applicable Rules.
The Purchasing teams ensure that Supplier activities respect Human Rights and fundamental freedoms. Suppliers included in the Risk Matrix are not listed in L’Oréal’s Supplier database until they have contractually committed to comply with the Applicable Rules. Purchasing teams discuss, during Management Committee meetings that include representatives from all Zones and purchasing areas, the results of audits, their consequences for commercial relations, and the related actions plans to achieve continuous improvement of results at the Group’s Suppliers.
