2025 Universal Registration Document

3. Risk factors and risk management

3.6.7.3 Results of the application of the Plan to Suppliers
Adoption of the Applicable Rules by Suppliers

The Mutual Ethical Commitment Letter, reviewed in 2002, sets out the requirements and commitments that L'Oréal imposes on its Suppliers according to the Group's programmes and policies concerning ethics, corporate responsibility, Human Rights, working conditions and compliance. 95% of eligible Suppliers(1), including strategic Suppliers, have contractually undertaken to respect the obligations it contains.

The Mutual Ethical Commitment Letter (MECL) was updated in 2025.

In addition, L'Oréal requires its Suppliers who provide outsourced labour to sign the External Workforce Agency Standards. This document reinforces their commitment to the protection of human rights, in particular with regard to the prohibition of forced labour and access to a whistleblowing system.

L’Oréal aims to reinforce responsible and transparent relationships with its partners and limit environmental and social impacts in line with the Group’s policies. This approach is a continuation of its efforts, as detailed in section 4.4.2.2 "Sustainable Purchasing Policy” of this document.

In 2025, 77 newly recruited purchasers in the Group completed an in-depth training programme on Responsible Purchasing.

Monitoring and control system

L'Oréal is taking action to continuously improving its Human Rights, Environment and Health and Safety policies and practices across its operations and supply chains.

It has assessed its Suppliers using EcoVadis for several years now. In 2025, 1,039 Suppliers conducted an EcoVadis assessment of their social, environmental and ethical policies, as well as the implementation of those policies by their own suppliers.

In February 2025, L'Oréal joined SEDEX, a global organisation that promotes responsible and ethical business practices in supply chains. This partnership brings significant benefits to L'Oréal's Suppliers, including simplified on-site audit processes and access to training on best-practice implementation. SEDEX also allows its members to standardise their requirements for Suppliers through its social audit standard, SMETA. The SMETA questionnaire is a recognised standard, regularly reviewed by experts and aligned with L'Oréal’s own standards.

In 2025, 1,499 social audits were carried out at L'Oréal Supplier sites. The Group puts in place initial audits which are followed up by further audits three years later. During these follow-up audits, the auditors verify the effectiveness of any remedial measures required as a result of the initial audit. A tool for social audits is used to plan the audits with the external service provider's system and to manage the results and action plans for all Suppliers concerned.

L'Oréal supports its Suppliers in their continuous improvement process. In 2025, 73% of audits resulted in a “Satisfactory” or “Needs Continuous Improvement” score. L'Oréal tracks the percentage improvement in this regard, building on the actions already implemented.

In 2025, it strengthened its system for monitoring the most severe cases (i.e., Zero Tolerance). This system follows clearly defined steps, involving the Supplier's commitment and subsequent action plan, L’Oréal’s validation of the action plan, implementation of the action plan and then verification by a new audit that the plan has been completed. In cases where L'Oréal's efforts fail due to the unwillingness or inability of the business partner to improve, L'Oréal reserves the right to terminate the relationship.

Concrete examples of L'Oréal's approach are provided below.

  1. Payment of recruitment fees

    In March 2025, an audit revealed that Bangladeshi workers had had to pay excessive recruitment fees to secure their jobs in Malaysia. L'Oréal assisted the Supplier, sharing resources and laying out concrete steps to follow. Further investigations were carried out by the Supplier with the assistance of a third party, which included interviews with workers in their local language and analysis of documentary evidence. The Supplier has undertaken to reimburse the recruitment fees paid by the affected workers. It has (i) introduced a "Zero Recruitment Fees" policy and (ii) brought recruitment in-house. It has also set up a whistleblowing and reporting system for employees. An initial follow-up audit organised by L'Oréal confirmed that the action plan had been duly implemented, with the Supplier having begun to reimburse the recruitment fees (the fees will be reimbursed over a 12-month period).

  2. Managing forced overtime

    An audit carried out in April 2025 revealed forced labour practices at a Supplier based in Brazil. Temporary staff were being forced to work unpaid overtime under threat of dismissal. Further investigations have been carried out to identify other temporary workers that may be affected. The Supplier agreed to recruit some of these workers and pay back wages based on the victims' testimonies. To limit the likelihood of future violations, the Supplier has strengthened its policy against forced labour, trained its managers in collaboration with the FLA, set up a whistleblowing and reporting mechanism and introduced regular checks and audits of timesheets. The follow-up audit organised by L'Oréal confirmed that the action and remediation plan had been duly implemented.