2021 UNIVERSAL REGISTRATION DOCUMENT

A process of integrating new sites

The Group regularly acquires new sites. A formal integration process then makes it possible to provide these sites⁽¹⁾ with extra support and assistance in order for them become compliant with all EHS requirements defined, and to bring potential risks under control.

The purpose of this process is to enable these sites to rapidly achieve the performance level expected by the Group.

It comprises:

1. a regulatory compliance audit carried out by an independent third party within six months of the acquisition;
2. deployment of the EHS processes described above(EHS manual, EHS reporting, training, audit programme); and
3. monitoring of the integration within the Group.

4.3.1.1.2. Managing risks and controlling the impact of sites on their environment

The Group systematically anticipates industrial risks of its activities, specifically the environmental impacts in the places where it operates, whether they concern soil, water or air.

Controlling and limiting risks to the environment

Each site has a general environmental analysis that must be updated on a regular basis and whenever a significant change occurs.

All activities performed by employees (permanent or temporary) are covered by an environmental aspects analysis, including routine and maintenance activities. The preventive measures described in the internal procedures must be complied with in order to avoid all forms of pollution (soil, surface water, groundwater, air, etc.). Contingency plans in the event of accidents are planned and are the subject of training for the people concerned. Proper implementation of these measures is verified during prevention inspections by insurers and periodic EHS audits.

Depending on the site, if significant risks are identified or if L’Oréal’s standards or regulations impose specific requirements, a more detailed evaluation is carried out for the activities concerned. Appropriate action plans – with immediate action where necessary – are implemented to reduce significant risks to an acceptable level.

Any establishment or site renovation, any introduction of new equipment or manufacturing processes, and any change in industrial processes is also the subject of a risk assessment and action plans to reduce the potential impacts. In the same way, at the time of purchasing land or buildings, L’Oréal conducts due diligence, which includes, in particular, a review of the environmental aspects.

Biodiversity and soil use

L’Oréal’s biodiversity and soil use commitments are based on the following principles:

• establish an ecological inventory of the site: the purpose of this inventory, through the resulting action plan, is to preserve, restore and develop the biodiversity of the site in its ecosystem. This inventory is performed by a local expert and may be based on the SITES v2 standards (Reference guide for Sustainable Land Design and Development), which is a ligned with the LEED environmental certification (Leadership in Energy and Environmental Design);
• reduce the impact of construction on the environment, for instance by choosing a zone that is already industrially developed, even an existing industrial site or brownfield site or, for administrative sites, an urban area with a high population density close to a residential neighbourhood, ideally located in the city centre or in a neighbourhood well served by public transport; a sustainable building site charter includes these recommendations and requires selective sorting of building site waste and minimised impact on residents during the project phase;
• if possible, place the site on land located more than 30 metres from any wetland (sea, ponds, lakes, rivers, etc.), outside natural areas, public green spaces, land with endangered or threatened species, or any other unbuilt areas (farmland, etc.);
• prevent soil erosion that may result from rainwater runoff or wind erosion during construction, inter alia by protecting the stored arable soil layer to enable it to be reused;
• maintain or restore native natural habitats and biodiversity on the built site;
• maximise green space areas or natural spaces on the site (even in excess of local regulations) and minimise impermeable surfaces;
• focus on cleaning up polluted sites (brownfield site) where development is more difficult due to environmental contamination (real contamination or contamination perceived as such), thus avoiding construction on natural or undeveloped land; and
• for future administrative sites, lease buildings that are certified LEED Gold or Platinum or equivalent in mature real estate markets.

Surface water

The Group has adopted standards for rainwater management in order to monitor its quality and avoid polluting it. For instance, sites are equipped with oil separators for parking areas. Similarly, any retention and operating area where accidental spills are liable to occur must have adequate retention capacities. Sites must also have retention capacity to contain fire extinguishing water.

In 2021, no accidental spill was recorded.

Industrial wastewater

31 L’Oréal factories have their own wastewater treatment plant. They use a range of technologies, including physical, chemical and biological processes adapted to the characteristics of the wastewater and local discharge conditions. L’Oréal continues to install wastewater treatment plants for its wastewater, as for example in india in 2021.

Equipment operation and wastewater management are the sites’ responsibility, and are subject to specific procedures and instructions. An internal audit or self-assessment of the corresponding facility is organised and documented at least once each year.

(1) Excluding stores.