Organizational Strategy - Sustainable Development - L'Oréal

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9 L’OréaL - GrI DaTa SHEETS 2011 through individual ethics interviews. These interviews use questions on corruption. They are conducted independently with the Country Manager and the administration and Finance Manager. They are subject to an individual report that is reviewed and signed by the aforementioned managers. SO3 L’Oréal monitors the number of countries that have integrated Human rights (health, hygiene and safety, diversity, moral and sexual harassment, privacy, community contribution, fair selection and treatment of suppliers) into its training. Country reporting Ethics is an annual reporting system on ethical issues. It covers all subjects mentioned in the Code of Business Ethics and thus provides an analysis of the initiatives in place in the countries. In particular, this information helps L’Oréal assess the group’s performance in enforcing Human rights. In 2011, 77% of the group countries included Human rights issues in their local training programmes. SO4 Country managers are responsible for implementing L’Oréal’s anti-corruption policy. This commitment is supported by Human resources procedures. Subsequently, the “Obtain results with integrity” competency is now included in the annual review system for all employees. at L’Oréal, training on Ethics addresses bribery and “facilitation payments” as well as gifts, entertainment and conflicts of interest. Within the scope of L’Oréal’s “Open Talk” culture, employees are encouraged to raise their concerns online. a dedicated, secure website enables them to ask their questions or submit their concerns directly to the group Ethics Director. L’Oréal’s internal audit teams are especially vigilant about this. The risks of corruption are systematically examined during these missions. Finally, the Country reporting Ethics, annual reporting system on Ethical issues in the group, helps track the group’s performance in this area. The tool for analysing and assessing ethical risk helps Country Managers evaluate risks in their country (including the risk of corruption) and take the necessary measures to eliminate this risk. PuBLIC POLICY I. CONTENTS CORE SO5 Public policy positions and participation in public policy development and lobbying. II. STATE OF THE L’ORÉAL’S POLICY IN 2011 SO5 as a leader in the cosmetics industry, L’Oréal believes that it has a responsibility to be proactive and participate in drafting local regulations in countries where it is present. This is why the group is committed to being involved in Cosmetics Europe (formerly Colipa), the reference professional association almost systematically solicited to speak to stakeholders and within different professional associations, such as the CaFFCI - the China association of Fragrance Flavour and Cosmetic Industries, ISTMa – the Indian Soap and Toiletries Mfrs association, the JCIa (Japan Cosmetics Industry association), PErKOSMI (Persatuan Kosmetika Indonesia), the Korea cosmetic association, The Cosmetic & Perfumery association of Hong Kong, the Taipei Cosmetic Industry association and the Vietnam Oil, aromatherapy & Cosmetics association in asia as well as the CaSIC and CONarS (for issues of self-regulation and advertising responsibilities) in South america. Each of L’Oréal’s directors of Public affairs is in charge of this lobbying in its geographic area, with the support of working groups of scientific and regulatory experts in the areas under discussion. For example, for hair dye products, L’Oréal has been very committed to the think tank in place on the subject, which involved scientific bodies and the European Commission. L’Oréal largely contributed to reassessing all of the ingredients that are used in hair dyes. L’Oréal is subject to the same laws as all companies and seeks to maintain an impeccable reputation. L’Oréal asks its subsidiaries to comply with the 6/8
9 L’OréaL - GrI DaTa SHEETS 2011 regulations of the countries in which they operate. as an active member of professional associations in the countries where its industry is represented, L’Oréal takes part in the ongoing dialogue between the local and regional authorities in charge of specific product regulations in its sector in order to prevent or adapt to any risks related to regulatory changes. The European rEaCH regulations (on the registration, Evaluation restriction and authorisation of CHemical substances), which entered into effect in June 2007, aim to reinforce the human and environmental safety of chemical products by obliging any company that uses such products to show proof that they take appropriate risk management measures. L’Oréal takes an active role in this process when it comes to substances that are manufactured or imported by its European legal entities. Within the national and European associative framework, L’Oréal takes part in analysing and drafting practical guides for implementing these regulations. In Europe, L’Oréal is also governed by the 7 th amendment of the European Cosmetics Directive, which prohibits animal testing for ingredients. a L’Oréal action plan was created to help develop ways to discover and assess the safety of raw materials. This plan benefits from expedited implementation. COMPLIANCE I. CONTENTS BASE II. STATE OF THE L’ORÉAL’S POLICY IN 2011 SO8 SO8 Monetary value of significant fines and total number of non-monetary sanctions for non- compliance with laws and regulations. Within the normal scope of its activities, the group is involved in legal actions and is subject to inspections by tax, customs and administrative authorities. It is also subject to procedures initiated by national competition inspection authorities, and especially in European countries. In order to prevent the risk of becoming subject to such inspections, the group Legal Department implemented training on competition law for relevant employees. also, in 2011, it distributed a legal and ethical guide on unfair competition practices, called, “Day-to-day competition”. a provision is booked each time the group has an obligation to a third party and must face the possibility of outgoing resources, the cost of which can be reliably estimated. L’Oréal deems that, to date, there is no highly probably exceptional event or governmental, legal or arbitrage procedure that is likely to significantly affect or that recently significantly affected the financial situation, assets or activity of the Company and L’Oréal. 7/8
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Organizational Strategy - Sustainable Development - L'Oréal

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