2021 UNIVERSAL REGISTRATION DOCUMENT

3. Risk factors and control environment

Additional procedures

L’Oréal also uses analyses and ratings provided by EcoVadis, an analytical company, to evaluate the policies implemented by the Suppliers, among others, in terms of the issues covered by the Vigilance Plan. This evaluation is an indicative guide that can be added to the audits described above.

By participating in the EcoVadis assessment, L’Oréal compares its environmental and social policy with the experts and the recommendations of external auditors qualified in the analysis of multi-sector risks. This is a useful rating for the continuous improvement of L’Oréal’s programme, but it also contributes to the transparency of industry practices. This assessment is used to select suppliers by taking their environmental and social performance into consideration.

L’Oréal is also a co-founder of the Responsible Beauty Initiative(RBI), a sector initiative created in 2017 with EcoVadis that brings together seven major players in the cosmetics industry for the sustainable transformation of the entire beauty supply chain.

(ii) Self-assessment system

Human Rights and fundamental freedoms

An annual ethics reporting system enables monitoring of the implementation of the Applicable Rules in the Subsidiaries, namely with regard to Human Rights and Fundamental Freedoms.

Environment, health and safety in the workplace

The Management Committees of L’Oréal Sites have self-assessment tools for their practices based on the audit standards provided to them, which enables them to implement an improvement plan, if required. These self-assessments are input data in the EHS risk audits.

To direct its performance:

  • Every year, each Subsidiary site defines and revises its safety and environmental roadmaps to achieve the targets set by the Group. It tracks EHS indicators monthly.
  • At Group level, the indicators are consolidated monthly by region and globally for the Group’s results.
  • A Greenhouse Gas Assessment is prepared annually (pursuant to the GHG Protocol).

3.4.6. Whistleblowing mechanism and reporting system

L’Oréal’s “Speak Up” policy enables employees and external stakeholders to report serious violations of Human Rights and fundamental freedoms, non-compliance of rules relating to the health and safety of people and respect for the environment, notably via a secure website (ethics whistleblowing channel) directly to the Chief Ethics, Risk and Compliance Officer.

3.4.7. Update on the effective implementation of the Vigilance Plan

This section provides the 2021 results of the application of the Vigilance Plan for Subsidiaries and Suppliers.

3.4.7.1. General results of whistleblowing mechanisms and reporting

The Group’s ethics whistle-blowing line (www.lorealspeakup.com) was opened in 2008, and then to all stakeholders outside the Group, including suppliers and subcontractors, in 2018. A new procedure to collect and handle reports was published. In addition, employees can use several other channels to raise their concerns (hierarchical line, dedicated local lines, etc.).

In 2021, there were 379 reports on potential non-compliance with the Applicable Rules, including:

  • 16 on sexual harassment, 11 of which were proven, in whole or in part, and which resulted in 7 departures from the Group;
  • 71 on bullying, 17 of which were proven, in whole or in part, and which resulted in 5 departures from the Group;
  • 22 on discrimination, 2 of which were proven, in whole or in part, which did not result in a departure from the Group;
  • 24 on health and safety, 4 of which were proven, in whole or in part, which resulted in 2 departures from the Group;and
  • none on environmental issues.
3.4.7.2. Results of the application of the plan to Subsidiaries
Adoption of the Applicable Rules by the Subsidiaries

The Applicable Rules are incorporated into the Group’s Subsidiaries’ internal rules.

94% of employees individually acknowledged the receipt of the Code of Ethics and 76% of employees have been trained using an e-learning training tool on ethics.

Each EHS manager and each person working in a factory or distribution centre is trained in the Applicable Rules on Health, Safety and the Environment (EHS). All new employees are trained in the Rules on Health and Safety in the workplace and the Environment, regardless of their work location.