2025 Universal Registration Document

4. Sustainability Report

4.9.2 Human rights policies

4.9.2.1 Human rights policy in the value chain

L'Oréal's Human Rights Policy, most recently updated in April 2025, underpins its ambition to see human rights respected throughout the value chain, which encompasses a wide range of products, supply countries and types of purchase.

The policy is based on the United Nations Guiding Principles on Business and Human Rights (UNGP) and 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 3.6.4.1). This includes efforts to trace and map value chains, risk monitoring by geographic area, raw material or business, and social audits (see section 3.6.5.2), human rights impact studies, including field 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;
  • 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 commits L'Oréal and its suppliers(1) 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 dedicated palm and wood 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

The Chief Corporate Responsibility Officer, a member of the Executive Committee, is responsible for overseeing the respect of Human Rights and Fundamental Freedoms in the Group. This mission has been entrusted to her by L'Oréal's Chief Executive Officer, to whom she reports. 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. Within the Operations Department, specifically Sustainable Purchasing, the focus on human rights in supply chains was reinforced in 2025 with the creation of a dedicated unit.

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 ambition 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.