Country Managers (or, for Corporate or Region staff, the members of the Group's Executive Committee to whom they report) are responsible for ensuring compliance with the Code of Ethics. The Chief Ethics, Risk and Internal Control Officer systematically meets each new Country Manager and the Group's senior executives to provide guidance about their role. Senior executives also benefit from a tool to help develop their ethics leadership as well as specific training courses.
The 80 Ethics Correspondents throughout the world assist members of the Executive Committee and Country Managers to implement the ethics programme. Led by the Group Ethics team, they act as a local point of contact for all employees.
The Chief Corporate Responsibility Officer, who is also a member of the Executive Committee, oversees the respect of Human Rights and Fundamental Freedoms in the Group.
Human Rights risks are mapped and regularly updated, including for suppliers and subcontractors (see section 3.6.3).
An annual reporting system is used to monitor the implementation of the Ethics and Human Rights programme. The Ethics, Risk and Internal Control Department informs subsidiaries of any areas for improvement. Ethics risks are systematically reviewed during audit assignments, through individual interviews conducted separately with the Country Manager and the Finance Director.
For prospective acquisitions, the Ethics and Human Rights questionnaire is used to help determine whether the target company takes account of risks, particularly those related to business ethics.
A specific and compulsory e-learning course on ethics is available for all Group employees. It was updated in 2023 following publication of the new Code of Ethics. As at 31 December 2025, 84% of the relevant employees had completed it. The Ethics, Risk and Internal Control Department also provides face-to-face training as part of ongoing training for managers and certain business lines (Buyers and Human Relations).
The evaluation of the overall performance of employees, and more specifically managers, takes into account compliance with the Code of Ethics and Ethical Principles. Regular communication with stakeholders and the setting up of internal working groups help to incorporate Ethics into new policies and strategic decisions.
A whistleblowing system, Speak Up (www.lorealspeakup.com), is available to all Group stakeholders, as well as a procedure for collecting and processing reports, which are used to manage any violations.
In 2025, 858 potential ethical violations were identified either via the secure platform, or via the Ethics Correspondents and local or international management. Reported cases are thoroughly examined, followed by appropriate measures where applicable(1). The global number of reports of discrimination, harassment (including sexual harassment) and corruption received at Group level worldwide is notified to employees on a regular basis, as is the number of fully or partially substantiated cases and the corrective measures taken. These elements are also included in the presentation of the Group's Ethics Policy to the Board of Directors.
The Group has held an Ethics Day since 2009. During this online event hosted by the Chief Executive Officer, Group employees can ask questions, anonymously if they wish, and discuss the day-to-day application of the Ethical Principles. Each member of the Executive Committee and each Country Manager also organises local ethics discussions. In 2025, 60 such sessions were held, with over 30,000 people logging on and more than 4,700 questions received from across the globe, underlining employees’ strong commitment to this subject. Employees also receive regular information about the Group's Ethics policy and have access to a dedicated Intranet site.
L'Oréal’s Corporate Social Responsibility (CSR) policy is mainly rolled out through its “L'Oréal for the Future” sustainability programme.
In this context, the Group has developed a governance structure (see section 4.1) that notably includes worldwide Sustainability Leaders. They are tasked with helping the Country, Region, Division and Brand Managers to implement the sustainability programme within their entities. The progress of local implementation of the Group's objectives is monitored by means of an annual reporting system.
Internal Audit regularly reviews sustainability risks, as well as the extent to which any policies adopted to address such risks have progressed. The results are then reported to the Audit Committee.
Since 2019, in collaboration with the Ethics, Risk and Internal Control Department, L'Oréal's Corporate Responsibility Department has conducted a deeper assessment of the risks associated with climate change and nature related to the Group's operations, referencing in particular the scenario analysis method. This was with a view to the departments improving their ability to anticipate and mitigate the impact of these risks. In addition to this risk assessment, and to meet its obligations under the Corporate Social Responsibility Directive (CSRD) as from 2024, the Group also conducts a double materiality assessment covering all CSR matters. These assessments allow the Group to precisely map the impacts, risks and opportunities in the various areas. Financial risks related to all CSR topics, and particularly climate change, along with the Group’s measures to reduce those risks, are described in chapter 4.
The talent and skills of the women and men employed by the Group are of paramount importance to L’Oréal. L'Oréal's Human Relations (HR) Department has always strived to support the Group's growth and transformation initiatives. L'Oréal's lasting growth depends first and foremost on the women and men in the Company, who are the key drivers of the Group's success. Built on this conviction, the Group's approach as an employer is based on individualised management of employees and on collective strength.
