4.9.2 Human rights policies
4.9.2.1 Human rights policy in the value chain
L’Oréal’s human rights policy underpins its determination to respect human rights throughout the value chain, which encompasses a wide range of products, supply countries and types of purchase.
The policy is based on the due diligence recommendations set out in the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct and is built on four core pillars:
- identification of salient risks: L’Oréal continuously identifies and assesses the risks of human rights violations based on the specific geographical, sectoral and operational context of its activities (see section 3.5.4.1). This includes efforts to trace and map value chains, risk monitoring by geographic area, social audits (see section 3.5.5.2), human rights impact studies, feedback through whistleblowing systems and regular engagement with external stakeholders;
- culture of respect: the Group trains its employees, shares best practices and integrates respect for human rights into its values and daily practices;
- stakeholder engagement: L’Oréal engages in active dialogue with its partners, takes their concerns into account and encourages them to set up transparent whistleblowing systems;
- roll-out of transformation action plans: insofar as the workers in the value chain are covered by the human rights policy and their operations by the sustainable purchasing policy, when L’Oréal identifies a human rights violation in its value chain, the Group implements an action plan to put an end to it. In some cases, this may require changing certain practices in the value chain; and
- collaboration: the Group works with other companies, NGOs and international organisations to attempt to find sustainable solutions to systemic human rights challenges.
Special attention is paid to conflict zones, in accordance with international standards.
In particular, L'Oréal recognises the rights of indigenous peoples, as defined by the United Nations Declaration on the Rights of Indigenous Peoples. The Mutual Ethical Commitment Letter (MECL) commits L'Oréal and its suppliers to respecting human rights, including those of indigenous peoples. L'Oréal also supports local communities through projects on the ground related to its value chain. This commitment is pursued through a number of initiatives, including:
- compliance with the principles of the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization, in line with the Code of Ethics;
- implementation of due diligence procedures on the ground (notably in line with the Group's forest policy) to identify and mitigate environmental and social risks (including for indigenous peoples). These include the “palm alert” procedure and Speak Up, which is communicated to all stakeholders, especially workers in the value chain, and used to report violations.
Dedicated governance for human rights
Human rights matters are the responsibility of the Chief Corporate Responsibility Officer, who reports directly to the Chief Executive Officer. Depending on the issues addressed, other teams, such as human relations and operations including purchasing and R&I may also be involved.
A network of more than 50 human rights correspondents plays a key role in embedding this culture in every Group entity. In addition, various bodies, including a Human Rights Committee for the supply chain, chaired jointly by the Chief Corporate Responsibility Officer and the Chief Operations Officer, met several times to discuss the implementation of the human rights policy and to inform decision-making.
4.9.2.2 Sustainable purchasing policy and forest policy
Purchasing is the responsibility of the Chief Operations Officer, who reports directly to the Chief Executive Officer.
L’Oréal wishes to promote sustainable sourcing and demands high social and environmental standards from its value chain. This commitment covers the two key areas of suppliers’environmental and social performance, including sustainable sourcing of raw materials, particularly from forests, in line with its forest policy.
To this end, L’Oréal promotes diversity, equity and inclusion and sets rigorous ethical standards for its suppliers, covering the protection of human rights and non-discrimination. The Mutual Ethical Commitment Letter is essential to obtaining buy-in from the Group’s suppliers. The letter commits suppliers to complying with strict human rights and environmental standards throughout their value chain, including within their own supply chain. Tier 1 suppliers are responsible for monitoring the corresponding measures put in place within their own value chain (see section 3.5).
In particular, L'Oréal expects its suppliers to:
- prohibit child labour: in accordance with the United Nations Convention, L’Oréal prohibits child labour and sets the minimum age for employment at 16;
- ban forced labour: L’Oréal firmly prohibits all forms of forced labour, including the confiscation of documents and non-compliant prison labour;
- ensuring social dialogue and freedom of association: suppliers must guarantee workers the right to associate freely and to bargain collectively without fear of reprisal. In situations or countries where the presence of independent trade unions is limited or discouraged, L’Oréal requires that workers be able, if they so wish, to come together independently to discuss work-related issues or express any concerns they may have;
- pay adequate wages: L’Oréal promotes the right to an “adequate” wage, which is essential for improving working conditions and reducing the risk of child and forced labour. The aim is for all employees of its strategic suppliers to ultimately earn an adequate wage;
- ensure occupational health and safety: L’Oréal requires its suppliers to identify and prevent risks and guarantee safe and decent conditions, with particular attention paid to vulnerable populations. The Group does not have a specific policy to promote long-term employment stability and sustainability for workers in the value chain;
- guarantee access to water and sanitation: all workers must be guaranteed access to drinking water and adequate sanitary facilities. This is enshrined in L’Oréal's Mutual Ethical Commitment Letter and is verified during social audits;
- combat violence and harassment: L’Oréal promotes an inclusive and respectful working environment, free from violence and discrimination, with special attention paid to the most vulnerable populations in the value chain.
