2025 Universal Registration Document

3.6.7.2 Results of the application of the Plan to Subsidiaries

Adoption of the Applicable Rules by the Subsidiaries

The Applicable Rules are incorporated into the Subsidiaries'internal rules. Employees learn through an online training programme on Ethics. At the end of 2025, 84% of the relevant employees had completed this training programme.

All EHS Managers and everyone working in a factory or distribution centre are trained in the Applicable Rules on EHS. All new employees are trained in the EHS Rules, regardless of their work location.

Monitoring and control system in respect of Human Rights

A total of 27 Group factories and distribution centres worldwide have been audited on their compliance with the Group's Human Rights Rules, apart from on compliance with health and safety rules, which is subject to specific separate audits. Five of these sites were audited as part of checks to determine whether the cases of non-compliance brought to light by the audits conducted in 2024 had been remedied.

On completion of the 2025 audit process and, where appropriate, remedial actions and compliance audits, the following cases of non-compliance were identified:

In terms of L'Oréal’s employees:

1. child labour: the audits did not reveal any cases of non-compliance;
2. forced labour: the audits did not reveal any cases of non-compliance;
3. freedom of association: an audit of one site revealed that the minutes of staff representatives' meetings had not been signed off for ten months;
4. non-discrimination: the audits did not reveal any cases of non-compliance;
5. working hours: the audits revealed that (a) employees at one site were sometimes required to work overtime; (b) the working hours of some employees at one site exceeded the overtime limit laid down in the Employee Human Rights Policy; (c) the rest days taken by employees at one site were organised on a fortnightly, rather than weekly, basis; (d) one site did not provide proof that workload meetings had been held; and (e) the minimum daily rest period for one employee had not been respected during on-call duty;
6. payroll: an audit revealed that the remuneration of employees at one site was not adjusted when they performed duties requiring a higher level of qualification than their usual duties;
7. sexual harassment and bullying: the audits did not reveal any cases of non-compliance;
8. disciplinary practices: the audits did not reveal any cases of non-compliance.

In terms of employees of external companies (temporary work agencies and subcontractors), the audits revealed (a) that one site was unable to demonstrate that it had taken measures to ensure that these companies adhered to L'Oréal's ethical standards and that the site managers did not have sufficient knowledge of the internal procedures applicable to the management of indirect employment; (b) non-compliant pay and benefits for employees of external companies at four sites; and (c) the lack of a procedure to verify the age of employees of external companies at one site.

Action plans have been drawn up for all these cases of non-compliance, with compliance audits to verify implementation scheduled for the first four months of 2026.

Monitoring and control system concerning EHS

In 2025, 80 "Top managers" (managers of factories or distribution centres, Management Committee members, etc.) attended the Leadership & Safety Culture seminar, held at the CEDEP, The European Centre for Executive Development, at the INSEAD campus in France. The seminar aims to raise awareness with top managers about safety issues, increase their leadership ability and see these behaviours adopted and maintained over the long term.

A total of 34 factories are certified⁽¹⁾ ISO 45001, representing 94% of the Group's factories. 34 are certified ISO 14001 (94%) and 28 are certified ISO 50001 (77%)⁽²⁾. In 2025, the following EHS audits were conducted:

• 13 risk audits;
• 21 combined EHS culture and risk audits;
• 12 combined Quality, Environment, Health, Safety and Performance audits; and
• 108 additional EHS audits of subcontracting sites in factories, and in external distribution centres and Suppliers.

The most frequently identified risks during EHS risk audits are related to fire protection, procedure safety, hazardous energy, containment of firewater run-off and wastewater management. Failures to comply and formal notice were systematically subject to corrective measures.

In 2025, failures to comply with regulations were found at ten factories with regard to the quality of their wastewater. Thanks to the Waterloop concept, all of L'Oréal's production sites will be able to improve their water treatment and recycling capacities.