2025 Universal Registration Document

4.9.3 Action plans in place

The Group applies its Sustainable Purchasing Policy via several main categories of measures:

• in-house training in responsible purchasing: L'Oréal regularly trains its buyers in the challenges of responsible purchasing, with a module dedicated to human rights, for example. This informs buyers of the vulnerability of certain groups such as indigenous peoples in terms of human rights. Training is compulsory for all onboarding buyers;
• supplier support and assessment: L'Oréal works closely with its direct suppliers to promote responsible social and environmental practices, particularly on matters surrounding human rights and adequate wages (see section 4.9.2.2). The Group prioritises transparency and uses various tools and processes to assess its suppliers. Suppliers located in countries identified as high risk by Verisk Maplecroft are subject to a compulsory social audit before being listed as suppliers at L'Oréal (see section 3.6.5.2). In early 2025, L’Oréal joined the Supplier Ethical Data Exchange (SEDEX) initiative, a global collaborative platform for managing and sharing ethical, social and environmental supply chain data. Membership of this platform helps reinforce L’Oréal’s oversight and supports the continuous improvement of working conditions and environmental impact among suppliers, notably by relying on the Sedex Members Ethical Trade Audit (SMETA) methodology. SMETA, recognised for its high ethical standards, facilitates in-depth assessment of social risks such as forced labour and freedom of association. The Group also conducts human rights impact assessments in at-risk regions and sectors, as well as field projects;
• roll-out of the Living Wage programme, aimed at committing strategic suppliers to the principle of an adequate wage, in line with the recommendations of experts (International Labour Organisation and IDH Sustainable Trade Initiative) and with the support of partners (Fair Wage Network and Wage Indicator Foundation). L'Oréal shares content (definitions, methodology, testimonials, etc.) on the Living Wage programme with its strategic suppliers via a platform. This content is also presented in a series of webinars. Suppliers are encouraged to sign a pledge and to work towards an adequate wage for their employees;
• contractual commitments: L'Oréal requires its suppliers⁽¹⁾ to sign the Mutual Ethical Commitment Letter, which notably informs them about reports submitted via the Speak Up platform;
• monitoring and complaints: L'Oréal has set up channels for reporting potential human rights violations. These include dialogue with stakeholders, the Speak Up platform (a secure, anonymous website that can be accessed by all stakeholders, with a system on hand around the clock and available in 30 languages, and performance monitored via indicators; see section 4.13.2) and the palm and wood fibre sector alert procedure⁽²⁾ that is available and communicated to all stakeholders, including workers in the value chain (see section 4.9.2.2). The oversight process is designed to ensure strict confidentiality, fair treatment, protection against reprisals and compliance with national legislation in the countries where the Group operates. If a violation of the human rights of workers in the value chain or affected communities is identified, the actions required depend on the specific context and are determined in light of an impact assessment and any information collected during discussions with stakeholders. The Group immediately engages in dialogue with its suppliers and implements a set of immediate measures aimed, if necessary, at identifying the precise source of the incident and rolling out action plans with the suppliers concerned. These action plans are aimed at implementing concrete, corrective measures in the short, medium and long term. To promote systemic change that helps resolve the root causes of certain violations and strengthens oversight systems across a given value chain, the Group may call on a range of key players, from NGOs to public authorities, local civil society organisations and companies in the beauty and perfume industry, etc.;
• involvement in coalitions and impact studies: L'Oréal is a member of coalitions such as the Consumer Goods Forum's Human Rights Coalition for Action as a means to boost its positive impact and its transformative potential. For example, in response to a human rights risk identified in the rose sector in Turkey, L'Oréal joined the Harvesting the Future initiative launched by the Fair Labor Association, aimed at improving working conditions and respect for human rights in various agricultural sectors, focusing on empowering seasonal workers and their families. Running up to end-2026, the project brings together various stakeholders, including the Turkish government, local civil society organisations, processors, growers and companies in the beauty and perfume industry, in order to support and strengthen the introduction of systems for monitoring human rights in their supply chains.