2025 Universal Registration Document

3. Risk factors and risk management

Everyone involved in preventing and detecting corruption
Everyone involved in preventing and detecting corruption
Executive Committee Regularly reviews the corruption prevention programme presented to the Board of Directors.
Ethics, Risk and Internal Control Department Reporting to the Chief Executive Officer, this department ensures that the programme is effectively rolled out at Group and entity level by performing second-level ex post controls.
Legal & Compliance Department Compliance teams within the Legal & Compliance Department are responsible for designing and monitoring the corruption prevention programme in collaboration with the departments involved in the programme (Purchasing, Finance, Human Resources, etc.). It leads the specific risk mapping process related to corruption risks.
Country Managers

Country Managers ensure the effective deployment of the corruption prevention programme and its compliance.

Their involvement in this issue is required on an annual basis by the Ethics, Risk and Internal Control Department, the Legal & Compliance Department and by their local Corruption Prevention Committee.
Corruption Prevention Committees

They oversee the progress of the corruption prevention programme within their entities and involve the Management Committee in an annual review of the programme.

They include the Internal Control Manager, the Chief Financial Officer, the Legal Director, the Human Relations Director and the Ethics Correspondent.
Internal Control Managers Supported by the Country Managers and the Chief Financial Officer, Internal Control Managers are responsible for overseeing the corruption prevention system in their entities.
Country Legal Directors Country Legal Directors manage the corruption prevention programme on a day-to-day basis in their entities, with the support of the Chief Financial Officer.
Employees Employees apply the anti-corruption policy in the context of their activities. In case of doubt or questions about compliance with these commitments, they may contact their line managers, the Legal Director, the Chief Financial Officer, the Internal Control Manager, the Ethics Correspondent and, ultimately, the Chief Ethics, Risk and Internal Control Officer.
L'Oréal's Code of Ethics and practical corruption prevention guides

L'Oréal's Code of Ethics publicly declares a zero-tolerance policy on corruption. It applies to all employees, directors and corporate officers and members of the Executive and Management Committees of the Group and its subsidiaries worldwide. L'Oréal's Code of Ethics was updated in 2023. Available in 30 languages, and as an audiobook in French and English, it is distributed to all employees worldwide.

L'Oréal has also published a more detailed corruption prevention policy that is available on its website, loreal.com.

The Group also has other reference documents for employees to specify the practices to be adopted to fight against corruption.

  • Specific Corruption Prevention Guide: rolled out throughout the Group as a whole since 2013 and supplemented in 2018, it covers the relationships with each of L'Oréal's stakeholders, in particular with the public authorities and with intermediaries. This practical guide is intended to specify the Group's standards and to help employees handle situations that they might encounter in the performance of their duties. It reaffirms L'Oréal's corruption prevention policy which was approved by the Chief Executive Officer and the Executive Committee. The policy was presented to the Board of Directors.

This policy posted online on L'Oréal's website restates the following principles:

  • the zero-tolerance policy on corruption;
  • the prohibition of facilitation payments;
  • the prohibition of any contributions to political parties or politicians with the aim of obtaining a commercial advantage;
  • the prohibition on giving and accepting gifts and/or invitations that might influence or be perceived as influencing a business relationship;
  • communication of the commitment to preventing corruption to the Group's business partners; and
  • respect for these commitments by intermediaries representing L'Oréal vis-à-vis public players, particularly in countries where there is a high risk of corruption.
  • Employee Guide – Gifts/Invitations: distributed in 2014 on a Group-wide basis, it sets out the rules in this area. This guide now forms part of the specific Corruption Prevention Guide, and a special register has been added to it for the Group's employees who are most exposed to corruption risks.
  • Employee Guide – Management of intermediaries with public authorities: issued in 2018 to the personnel concerned, it specifies the rules in this area.
  • The Way We Work with our Suppliers: distributed in 2022, this guide specifies the rules concerning relationships between suppliers and any employees involved in purchasing decisions.
  • The Way We Do Philanthropy: distributed in 2021, this guide specifies the rules surrounding providing corporate philanthropy in compliance with Ethical Principles, the Code of Ethics and the Group's in-house standards.
  • The Way We Work with Scientific and Healthcare Professionals: updated in 2023, this guide helps the Group's employees to work with these third parties in an ethical manner.
  • Responsible Interactions with Journalists: distributed in 2024, these guidelines help Group employees comply with the Group’s ethical rules in their interactions with journalists.
  • Responsible Lobbying Policy: distributed in 2021, this policy specifies the responsible lobbying commitments and how they should be implemented.
  • Conflicts of Interest Policy: issued in 2023, this policy governs the definition of conflicts of interest and the procedure for reporting and managing such conflicts.