L'Oréal Code of Ethics (4th Edition) PDF

we CODE OF ETHICS THE WAY ACT 4 TH EDITION L’Oréal was built on strong Acting ethically creates trust values and solid ethical with all our stakeholders. principles. They must be Without trust, L’Oréa...

we CODE OF ETHICS THE WAY ACT 4 TH EDITION L’Oréal was built on strong Acting ethically creates trust values and solid ethical with all our stakeholders. principles. They must be Without trust, L’Oréal cannot embodied in the way we act. develop in the long term. At L’Oréal, Ethics is built first and Because our culture of integrity foremost on trust. Our Code of is the guarantee of our Ethics inspires our choices and sustainability, the ambition of the helps us make better decisions. Board of Directors, shared by all, is It is a constant challenge, but to continue to be one of the most also a fantastic opportunity exemplary companies in the world. for continuous improvement. Jean-Paul Agon Chairman of the Board of Directors 01  FOREWORD Our strong ethical culture is Respect of our Code of Ethics INTRODUCTION one of the pillars of L’Oréal and and our Ethical Principles in ETHICAL PRINCIPLES deeply connected to our Sense our strategic priorities and SPEAK UP of Purpose to Create the beauty transformation is our licence HUMAN RIGHTS that moves the world. The to operate. This is why we will Code of Ethics exemplifies our always support our employees leadership culture based on our and partners when they wish AS A BUSINESS demanding Ethical Principles. It to raise a concern regarding is our compass, which empowers the respect of our ethical AS AN EMPLOYER and guides us in a world of commitments. L’Oréal’s reputation, unprecedented uncertainty and the trust of our stakeholders transformations, where it can and the greater society rely AS A RESPONSIBLE be difficult to find landmarks. on our capacity to sincerely CORPORATION live up to our responsibility. Our ethics programme is widely CONTACT recognised and places us amongst Together with the Executive the leading companies in the Committee, I make a personal world. We have updated our Code commitment to follow this of Ethics to reflect the world we Code in letter and in spirit. operate in and the new challenges We count on you to do the same. that our teams are facing. Live i t a n d pass i t on. Nicolas Hieronimus CEO 02 Th e way we THE WAY ACT I act The way I act At L’Oréal, we share a common Sense Ethics guides us. It helps us answer of Purpose to Create the beauty important questions, like what we that moves the world. Ethics is at will always, or on the contrary, never the heart of our purpose and of do. Ethics elevates the role we play everything we do and how we do it. in society and as a global citizen at THE WAY Group level. We rely on ethics when The way we act and the choices there are no laws to guide us, when the we make as individuals and as a situation is opaque and unprecedented. I A CT Group define us and are the tangible embodiment of our Ethical Principles. By simply asking “What is the right thing to do?”, we see clearer and take better decisions. Every time. 03 CONTENTS Introduction AS A Business AS AN Employer WHY DO WE HAVE A CODE OF ETHICS? 06 MAKING SAFE, QUALITY PRODUCTS 14 ENSURING THE RIGHT WORKING CONDITIONS 38 HOW TO USE OUR CODE 07 CONDUCTING RESEARCH AND THE LEADERS’ AND MANAGERS’ ROLE 40 INNOVATION WITH INTEGRITY 16 OUR ETHICAL PRINCIPLES 08 PROMOTING DIVERSITY, EQUITY AND 42 COMMUNICATING RESPONSIBLY 18 ETHICAL DECISION TREE 09 INCLUSION (DE&I) PROMOTING RESPONSIBLE RESPECTING HUMAN RIGHTS 10 USAGE OF TECHNOLOGY 20 ENSURING RESPECT AT WORK 44 SPEAK UP: HOW TO RAISE AN ETHICAL CONCERN 11 HANDLING PERSONAL DATA WITH CARE 22 PROTECTING CONFIDENTIAL INFORMATION BUILDING STRONG RELATIONSHIPS 24 AS A R es ponsib le C or po ra ti on WITH OUR BUSINESS PARTNERS 25 RESPECTING PLANETARY BOUNDARIES 46 TREATING OUR COMPETITORS FAIRLY 27 CONTRIBUTING TO A BETTER SOCIETY 48 PROTECTING L’ORÉAL’S REPUTATION 29 ENSURING THE RIGHT USE PROMOTING RESPONSIBLE LOBBYING 49 OF COMPANY RESOURCES 31 BEING A RESPONSIBLE TAX CITIZEN 51 BEING OPEN ABOUT CONFLICTS OF INTEREST 33 FIGHTING CORRUPTION 34 PREVENTING FRAUD AND OTHER ILLICIT ACTIVITIES 35 04 4  ti o n INTRODUCTION uc ETHICAL PRINCIPLES o d HUMAN RIGHTS Intr SPEAK UP AS A BUSINESS AS AN EMPLOYER AS A RESPONSIBLE CORPORATION CONTACT WHY DO WE HAVE A CODE OF ETHICS? 06 HOW TO USE OUR CODE 07 OUR ETHICAL PRINCIPLES 08 ETHICAL DECISION TREE 09 RESPECTING HUMAN RIGHTS 10 SPEAK UP: HOW TO RAISE AN ETHICAL CONCERN 11 05  WHY DO WE HAVE A CODE OF ETHICS? INTRODUCTION Our Code of Ethics is our daily guide. It helps No document can anticipate and address every ETHICAL PRINCIPLES us understand what is expected from each situation that may arise. Over the next decade, HUMAN RIGHTS of us as members of the L’Oréal community, we will probably face new ethical dilemmas. We SPEAK UP and identify the topics which require special recognise that in some situations, making decisions care so that we can live up to our demanding is not easy. Our Code of Ethics sets standards for the Group and offers guidance in a number of AS A BUSINESS Ethical Principles and our commitments. ‘grey areas’ where an informed decision is required. L’Oréal operates in many countries – each home to a The golden rule is to disclose and consult. Discuss the AS AN EMPLOYER wide variety of cultural and legal environments. We as a matter openly with your manager, internal experts or business and as individuals must always respect the laws Ethics Correspondent before acting. Our Ethical Decision and regulations of the countries in which L’Oréal operates. Tree can also help deal with unexpected situations. AS A RESPONSIBLE CORPORATION The Code of Ethics helps us ensure that we apply the The Code of Ethics applies to all employees of the L’Oréal same ethical standards wherever we operate. There Group and its subsidiaries worldwide. It also applies to may be instances when the Code is at variance with all corporate officers and members of the Executive Th e way w e act in CONTACT the local law or customs of a particular country. If that and Management Committees of the L’Oréal Group is the case, where local law or customs impose higher and its subsidiaries worldwide as well as all employees al l o ur act ivit ie s standards than those set out in the Code, local law and and corporate officers of the Fondation L’Oréal. In case customs should always apply. When faced with conflicting of breach of this Code, L’Oréal reserves the right to r e fl e ct s o ur requirements between local laws and our Code of Ethics, take the action deemed appropriate in the situation. we will always seek ways to honour the standards set d e m a n din g e t hic al out in our Code, unless this results in illegal activity. We actively seek out and favour business partners pr in c ipl e s. W e c o u nt who share our ethical standards as described in this Code with regards to human rights, working conditions, o n yo u t o l iv e u p t o environmental stewardship and business integrity. We are committed to supporting partners in meeting these The standards set out in t h e c om mit m e nt s o f standards whilst having the courage, if necessary, to end this Code are not optional: relationships with those who are unwilling to meet them. we must respect them. We set the example: L’Oréal’s o ur C o d e. reputation and the trust of our J ea n - C h r i s stakeholders depend on each of us. t o p h e S a ut o r y, C hi e f E t hic We are evaluated not only on what s O f fi c e r we do, but also on how we do it. 06  HOW TO USE Our network of Ethics Correspondents around the world OUR CODE are a resource for you if you have INTRODUCTION The code is split into three sections, questions on ethics. Their role is to ETHICAL PRINCIPLES each with multiple chapters. mobilise, counsel and coordinate with local teams and experts. Business HUMAN RIGHTS SPEAK UP They have a direct functional reporting line to the Chief Ethics, AS A BUSINESS Employer Risk & Compliance Officer. Responsible Corporation AS AN EMPLOYER Each chapter specifies what we Because the world changes fast, will and will not do. For example: we need to update the Code of Ethics AS A RESPONSIBLE CORPORATION WE WILL regularly. The Code may be amended at any time when deemed appropriate.   Provide clear information on our CONTACT products and ingredients. The English version of the Code is WE WILL NOT the reference document. The Code is available in written and in audio format   Put any product on the market which does not in English and French. Additional local respect our high safety and quality standards. translations are available. It is publicly available on L’Oréal’s corporate website. FAQs In each chapter, you will find some Q&As, concrete illustrations of how we implement The Code aims to provide a framework our commitments in daily situations. for all our internal policies and standards. In particular, ethical policies Additionally, you will find proof points of how L’Oréal and the Fundamentals of Internal puts ethics in action and ways in which you can do the same with useful resources and points of contact. Control are available to provide guidance on specific topics. E thics in action How can you act ? 07  OUR ETHICAL PRINCIPLES INTRODUCTION Our Ethical Principles show people what ETHICAL PRINCIPLES HUMAN RIGHTS they can expect from us and guide SPEAK UP our commitments and responsibilities. Integrity Respect They contribute to our reputation AS A BUSINESS as a trustworthy and respected Because acting Because we strive with integrity is to have a positive ethical business, and, together, they vital to building and impact on our AS AN EMPLOYER underpin our shared desire to Create maintaining trust and stakeholders. the beauty that moves the world. good relationships. AS A RESPONSIBLE CORPORATION CONTACT Courage Transparency Because ethical Because we must questions are rarely always be sincere and easy but need to justify our actions. be addressed. 08  ETHICAL DECISION TREE This Ethical Decision Tree can help you work out the right approach, in line with our Code INTRODUCTION of Ethics, internal policies and Ethical Principles. Our Ethical Principles can help you navigate ETHICAL PRINCIPLES Are you facing a situation and are not through these situations. Ask yourself: HUMAN RIGHTS sure which decision you should make? In any case, all your actions and decisions must SPEAK UP be in line with your local laws and regulations. Integrity Are you doing the right thing without exception? AS A BUSINESS Would this impact the trust If it is not legal, do not do it NO: Do not do it of our partners or consumers? AS AN EMPLOYER Respect AS A RESPONSIBLE Are you treating others as you CORPORATION Is the decision you The situation would like to be treated? Check with need to make in is not covered Would it negatively impact CONTACT your legal people or the planet? line with the Code within the Code team whether of Ethics and/or of Ethics nor any it is legal Transparency internal policies? internal policies Would you like to see this all over the internet? Would you be able to easily justify your decision? YES: Go ahead Courage Are you standing up for the way we act? Would this be considered appropriate years from now? ETHICAL QUESTIONS ARE NOT EASY BUT MUST BE ADDRESSED. YOU ARE NOT ALONE! Discuss the situation openly with your manager or Ethics Correspondent. 09  RESPECTING HUMAN RIGHTS INTRODUCTION ETHICAL PRINCIPLES We are committed to HOW WE RESPECT HUMAN RIGHTS Human Rights in action HUMAN RIGHTS respecting human rights, Mitigating our impacts When sourcing our raw materials, we check if SPEAK UP wherever we operate. L’Oréal is a company made up of human beings this could impact Indigenous Peoples and if this is the case, we make sure that their rights are whose actions and products impact people as well Our respect for human rights is based on as our planet. As such, it is our responsibility to respected, in particular rights related to their AS A BUSINESS land, in line with Free Prior Informed Consent all internationally recognised human rights ensure that we respect human rights, by mitigating standards, in particular the International Principles, as well as their traditional knowledge. negative impact resulting from our activities and AS AN EMPLOYER Bill of Human Rights (1948 Universal by developing our positive impact where we can. We are committed to ensuring that all employees Declaration of Human Rights and the two receive at least a living wage covering their basic covenants), on the 2011 United Nations Mapping and managing issues needs and calculated in line with best practices. By AS A RESPONSIBLE Guiding Principles on Business and Human CORPORATION We aim to ensure respect for human rights within 2030, 100% of our strategic suppliers’ employees Rights and on the International Labour will also be paid at least a living wage. our own operations and with our business partners, Organization’s Core Conventions. by trying to find out who we impact the most and CONTACT What human rights mean how (i.e. human rights due diligence process). To help us embed our commitments, we work with internal How can you act ? and external human rights experts to identify and Several chapters of the Code of Ethics help us ensure we Human rights are relevant to everyone address parts of our business where we impact people respect our human rights commitments, namely Making and impact us all on a daily basis. L’Oréal the most (i.e. our salient human rights issues). safe, quality products, Communicating responsibly, promotes respect for all internationally Handling personal data with care, Building strong recognised human rights and fundamental Developing a culture of transparency relationships with our business partners, Ensuring the freedoms, including the right to: We are transparent about our achievements and right working conditions, Promoting Diversity, Equity & Not be discriminated against challenges. We encourage our stakeholders, including Inclusion, Ensuring respect at work, Respecting planetary the most vulnerable ones, to raise any human rights- boundaries, and Contributing to a better society. Have a decent job related concerns or issues they may be facing because Read our Group Human Rights policy and Freedom of expression of our activities, through various grievance mechanisms, Employee Human Rights policy. and in particular through our Speak Up policy. We Health A few interesting reference documents engage with NGOs to help us embed our commitments. Life and safety you may wish to read are: We do not inhibit the lawful actions of human rights Privacy defenders or restrict their freedom of expression, UN Declaration on the Rights of Indigenous Peoples freedom of association, or right to peaceful Convention on Biological Diversity and the Nagoya assembly, including those who actively campaign Protocol on Access and Benefit Sharing on issues that may be linked to our business. We share this policy with our business partners. UN Declaration on Human Rights Defenders. 10  SPEAK UP: HOW TO RAISE AN ETHICAL CONCERN INTRODUCTION We speak. We progress. ETHICAL PRINCIPLES HUMAN RIGHTS Being able to quickly identify ethical misconduct is key to SPEAK UP ensuring we live up to our Code of Ethics and our Ethical Speak Up Guidelines Principles throughout all our activities and geographies. AS A BUSINESS We encourage a culture of openness where employees and our CONFIDENTIALITY PROTECTION external stakeholders can raise their concerns. Confidentiality is key to ensure you feel Employees or external It is important to ensure that all concerns are supported by safe to raise your concerns. Therefore, all stakeholders making a Speak AS AN EMPLOYER Speak Up reports are only shared with Up report or involved in an consistent and detailed facts. the persons involved in handling the case investigation should never be We recognise that speaking up is not always easy and can be strictly on a ‘need-to-know’ basis. sanctioned for having shared AS A RESPONSIBLE CORPORATION intimidating. We have two channels that are trustworthy and in their concerns in good faith. If someone shares confidential The reputation of people unjustly line with whistleblowing best practices. You can raise your information regarding a past or ongoing accused is also protected and ethical concern through the normal management channels CONTACT investigation, please contact your Ethics Speak Up reports made in bad (members of the Group’s Executive Committee, members of a Correspondent or the Global Ethics faith can lead to sanctions. In case Group, Zone or Country Committee, Country Managing department directly. If you prefer, reports of retaliation after speaking up, Director or Ethics Correspondent) or directly to the Global can be made anonymously via our public please contact directly the Global Ethics, Risk & Compliance department through our secure secure website: www.lorealspeakup.com. Ethics department or use the website www.lorealspeakup.com. In addition to whatever Speak Up platform. protection is afforded by national laws in the countries in which All investigations are managed we operate, our Speak Up policy sets a global framework on a dedicated system hosted on ACCOUNTABILITY providing clear guidelines. an encrypted platform, so that all The Global Ethics department and information relating to investigations Ethics Correspondents oversee Our Speak Up programme enables L’Oréal internal and is protected. all Speak Up investigations. external stakeholders to raise any serious ethical concerns they The Group’s Chief Ethics Officer EQUAL TREATMENT may have so that the Group and the Global Ethics department directly handles any concerns All Speak Up reports are reviewed, can address them. Speaking up gives us the chance to make relating to top management. and, if required, corrective measures things right where needed and ensures that we uphold our are taken regardless of the seniority responsibilities. level of the person involved or if they are internal or external stakeholders. In case of any doubt, don’t hesitate to speak up: you should not Conclusions are only based on facts assume your concerns are known at the right level of the and tangible information gathered organisation. If your concern is not admissible according to our during the investigation. Speak Up policy, we will redirect you to the appropriate department, with your prior consent, while always respecting the confidentiality of your identity. 11  SPEAK UP REPORTS IN ACTION INTRODUCTION ETHICAL PRINCIPLES HUMAN RIGHTS SPEAK UP STEP 1 E thics in action Reception You can go directly to www.lorealspeakup.com here. AS A BUSINESS After receiving a concern, the person making a Speak Up report will usually be contacted AS AN EMPLOYER to gather additional information. STEP 4 Investigation report and remedial actions AS A RESPONSIBLE CORPORATION Based on a report shared STEP 2 Scan the QR code among the Global Ethics to access the L’Oréal Admissibility assessment department, Human Relations CONTACT Speak Up platform. Based on the information and management, specific received from the reporter, Ethics conclusions are communicated Correspondents or the Global to the relevant people involved. Ethics department assess if Appropriate remediation the allegations fall under the actions, that can include scope of the Speak Up policy. individual sanctions, are undertaken by management and Human Relations. STEP 3 Investigation STEP 5 An investigation is required to Follow-up assess the reality of the facts based If necessary, the reporter on evidence that can be gathered through interviews, witnesses and will be contacted after the investigation to ensure that How can you act ? documentation. An investigation they are not facing any Contact your Ethics Correspondent can last several months depending retaliation from speaking up. and read the Speak Up policy. on its complexity. 12  LIVING UP TO OUR COMMITMENTS AS A ness INTRODUCTION us i ETHICAL PRINCIPLES B HUMAN RIGHTS SPEAK UP AS A BUSINESS AS AN EMPLOYER AS A RESPONSIBLE CORPORATION MAKING SAFE, QUALITY PRODUCTS 14 CONTACT CONDUCTING RESEARCH AND INNOVATION WITH INTEGRITY 16 COMMUNICATING RESPONSIBLY 18 PROMOTING A RESPONSIBLE USAGE OF TECHNOLOGY 20 HANDLING PERSONAL DATA WITH CARE 22 PROTECTING CONFIDENTIAL INFORMATION 24 BUILDING STRONG RELATIONSHIPS WITH OUR BUSINESS PARTNERS 25 TREATING OUR COMPETITORS FAIRLY 27 PROTECTING L’ORÉAL’S REPUTATION 29 ENSURING THE RIGHT USE OF COMPANY RESOURCES 31 BEING OPEN ABOUT CONFLICTS OF INTEREST 33 FIGHTING CORRUPTION 34 PREVENTING FRAUD AND OTHER ILLICIT ACTIVITIES 35 13  MAKING SAFE, QUALITY PRODUCTS We are committed to ensuring the safety and quality of our products, everywhere INTRODUCTION and always. Since the beginning, innovation and ethics have been central to L’Oréal – ETHICAL PRINCIPLES starting with finding a way for people to dye their hair safely. Product safety and quality HUMAN RIGHTS have always been paramount and the first building block of our consumers’ trust. We SPEAK UP ceased testing our products on animals in 1989 and strive to end this practice in our industry, contributing to the development and acceptance of alternative methods. AS A BUSINESS WE WILL WE WILL NOT AS AN EMPLOYER  rovide clear information on our P  ut any product on the market which does not P products and ingredients. respect our high safety and quality standards. AS A RESPONSIBLE CORPORATION  nsure that our sub-contractors and suppliers E  orego our scientific integrity for the benefit F Every for mula respect our safety and quality standards. of faster product development or influence  ake action or Speak Up if we become aware T or modify evaluation and test results. of each new pr oduct goes CONTACT of any product safety or quality issue. thr ough str ict safet y & qualit y checks befor e being industr ialised. ophie , P r o d uc t -S r ial i sa t io n. indust 14  FAQs What do we do with ingredients Why do people still believe that subject to controversy? we test our products on animals? Safety is our number one duty towards We have been at the forefront of INTRODUCTION our consumers. We want them to use alternative methods for decades and ETHICAL PRINCIPLES our products with complete trust, safe we completely ceased testing our HUMAN RIGHTS in the knowledge that each ingredient products on animals in 1989, 14 years SPEAK UP has been meticulously selected and before it was mandatory. Unfortunately, thoroughly vetted, thanks to rigorous some health or consumer authorities AS A BUSINESS systems allowing us to monitor every step of our development process. in certain countries may decide to conduct animal tests themselves. This E thics in action can make the situation difficult to Each L’Oréal product undergoes approximately 100 We are transparent about the understand sometimes. We are proud to quality controls before being put on the market. AS AN EMPLOYER ingredients we use, notably through be amongst the most active companies our platform Inside our Products. in promoting alternative methods. When there is a debate about the AS A RESPONSIBLE safety or environmental impact of CORPORATION an ingredient, we monitor this closely and work with our stakeholders to investigate further. If there is a proven CONTACT or strongly suspected risk, we will stop using it, whatever the cost. How do we ensure that our new acquisitions or subcontractors really respect our standards? When we acquire a new brand or plant or when we subcontract our manufacturing, How can you act ? there is always a review and, if necessary, Read our Human Rights policy and our ethical guides an action plan to ensure the plant The Way We Work with Scientific and Health Care or the subcontractor measure up to Professionals, The Way We Conduct Cosmetic Predictive our quality and ethical standards as quickly as possible. This can lead us Evaluation and The Way We Conduct Cosmetics to change subcontractors, if necessary. Studies Involving Volunteers or Consumers. The Inside Our Products site also contains useful information. There may be specific policies on product safety and quality that apply to your activity or in your entity. Contact your Quality Director or Scientific Director for more details. 15  CONDUCTING RESEARCH AND E thics in action INNOVATION WITH INTEGRITY L’Oréal benefits from a Scientific Ethics INTRODUCTION We are committed to ensuring the quality and relevance of our scientific Advisory Committee to address questions ETHICAL PRINCIPLES projects, the objectivity, reliability and reproducibility of our data and the coming from R&I employees. HUMAN RIGHTS transparency and truthfulness of our scientific communication. SPEAK UP This Committee is based on an internal The ethics of our research and innovation activities and the integrity of our data network of Scientific Ethics Referents. have always been paramount and a guarantee that we make effective and unique AS A BUSINESS products for consumers. Our responsible research, maintaining the reputation and credibility of science, is a building block of our consumers’ trust. AS AN EMPLOYER WE WILL WE WILL NOT AS A RESPONSIBLE CORPORATION  onsider the impact of our projects with respect C  ake any risk with regard to safety, human T to people, society and the environment, in order to health and the environment, considering preserve the wellbeing, health, privacy and freedom current scientific understanding. CONTACT of people as well as save natural resources.  orego our scientific integrity for the benefit F  e particularly vigilant using an algorithm: B of faster product development or influence the approach must be proportional to the risk incurred, whether the algorithm is used or modify evaluation and test results. How can you act ? to design or optimise a cosmetic material Read our ethical guides Scientific Integrity of R&I, The Way or formula or whether it is used to classify or We Work with Scientific and Health Care Professionals, issue recommendations for consumers. The Way We Conduct Cosmetic Predictive Evaluation and The Way We Conduct Cosmetics Studies Involving  ct with respect and loyalty regarding A Volunteers or Consumers, The Way We Work with the work and expertise of other scientists and be respectful in our interaction with Suppliers, and Principles for Trustworthy AI. L’Oréal’s external partners: scientific teams, service policies 10 Points of Vigilance for Responsible Product providers, subcontractors and suppliers. Communication and 10 Points of Vigilance for Data Privacy and Social Media also contain useful information. Base our scientific communication Contact your Scientific Director for more details. only on the formulation of scientific hypotheses and their factual verification, regardless of their value and nature. 16  FAQs How can we create an ‘out of the box’ What should I do if I observe that mindset to challenge scientific dogma? there are contradictory external In research, dogmas are made to be scientific data or publications that INTRODUCTION could invalidate my own data? questioned. L’Oréal, and in particular its ETHICAL PRINCIPLES R&I, are by nature open to new ideas. Data contradicting our own findings HUMAN RIGHTS may indeed exist in the literature. Above SPEAK UP As scientists, we may have the all, as scientists, we will carefully verify impression that we are blocked when we that our own research work relies on submit proposals at odds with current prior quality data. We know however AS A BUSINESS programmes. In this case, we start that some scientific results are not by documenting our point of view. reproducible and include biases. AS AN EMPLOYER We also build our argument by asking If a publication is contradictory to for the opinion of colleagues or experts our findings, we take this into account in the field. Then, we explain our and demonstrate critical thinking. AS A RESPONSIBLE point of view within the framework In addition, it is necessary to seek CORPORATION of scientific debate. Once this the reason for the inconsistency. This debate has been held, we will respect may be due to an error on our part management guidelines and we will in the management of the study or CONTACT follow the decision made on the choice the interpretation of the findings, but of the project’s scientific guidelines, also to biases in the publication. complying with our Code of Ethics and the guide Scientific Integrity of R&I. From my point of view, certain evaluation study data is clearly wrong and/or could create a bias against the product tested. What should I do? Any data set is to be handled as is, without any changes. Under no circumstances may data disappear or be removed voluntarily because it creates a difficulty. Data regarded as abnormal must be identified as such, and their eventual non-inclusion in results processing must be duly justified and tracked, in agreement with the study manager. 17  COMMUNICATING RESPONSIBLY Transparency and integrity are key when communicating about L’Oréal, its brands INTRODUCTION and products. We are conscious of the beauty images we project and the impact ETHICAL PRINCIPLES they may have on the lives of millions of people around the world. Together with HUMAN RIGHTS our agencies, we therefore need to ensure this impact is always positive and SPEAK UP respecting and promoting the infinite diversity of beauty needs and desires. AS A BUSINESS WE WILL WE WILL NOT  nsure that the advertisement and commercial E  romote unhealthy or unrealistic beauty P AS AN EMPLOYER communication on all media are sincere, aspirations and personal benefits. true, non-misleading and decent.  eek to exploit our consumers’ or stakeholders’ S AS A RESPONSIBLE  im to be inclusive towards people of every A lack of knowledge or lack of experience. CORPORATION ethnicity, social background, religion, gender, sexual orientation, age or disability.  ndermine human dignity in our U advertising, present degrading stereotypes CONTACT  e extremely cautious when promoting B or disrespect minority communities. t r i v e f o r products to children and young people. W e s  eliberately exaggerate claims D w e p o s t  arefully manage the relationship C in our communications, including with people who recommend our products environmental or societal claims. e v e r yt h i n g a c k e d (e.g. influencers, social sellers, bloggers, onlin e t o b e b vloggers, journalists, doctors) and  ommunicate in media environments C which publish content linked to violence, fi c be transparent about it. by s o l i d s c i e n t i incitation to hatred and sex.  nsure we respect advertising laws and E a n d w e c o m p l y  pecifically target young people under 16 except for S data the usage of third-party assets. dermatological, hygiene and sunscreen products. r i n t e r n a l  nsure that all copyrights, author rights, E personality rights and usage rights are respected. w it h o u n p r o c e s s e s. val i dat io  nsure all claims and statements are E based on solid data and comply with our internal validation process. - Mar inelle , ia & e n g ag e m e nt​ Social m e d 18  FAQs What can we say to people who What is our position regarding feel that we are promoting an advertising and children? unrealistic model of beauty? The only products we sell specifically INTRODUCTION ETHICAL PRINCIPLES HUMAN RIGHTS Beauty has always been aspirational and we embrace the infinite diversity aimed at children are dermatological, hygiene and sunscreen products. When E thics in action of beauty aspirations. We aim to give children appear in our advertising, we are SPEAK UP We do not work with models with a a fair, precise and truthful description especially vigilant about their working of our products and their effects. We conditions. We do not encourage the Body Mass Index (BMI) below 18. cannot mislead our consumers to believe daily use of cosmetics for consumers AS A BUSINESS in unachievable effects of our products under the age of 16. We do not use through the use of pre-production models aged under 16, except for our or post-production techniques. For child-specific products. On online AS AN EMPLOYER example, we only use visual retouching platforms, we adapt our advertising techniques to correct technical issues to take into account the age of users. such as untrue results due to lighting AS A RESPONSIBLE and never to enhance perceived product CORPORATION What are we allowed to claim performance. We also seek to ensure with regards to the presence or the models we use are representative absence of a specific ingredient? of a wide diversity of beauty types and CONTACT We cannot suggest that the presence do not use techniques to alter their physical appearance, age or skin tone. or absence of a particular ingredient offers greater safety to consumers if How can you act ? we are simply respecting the law (e.g. no hexachlorophene). The presence Read our Human Rights policy, our Social Media of ingredients that have no effect in policy, the L’Oréal Influencer Value Charter, the the formula cannot be used for claims. L’Oréal Social Commerce Value Charter, The Way We Finally, we are careful in the way we Work with Scientific and Health Care Professionals, communicate on ingredients which could The Way We Do Philanthropy guide as well as be perceived as controversial (e.g. hemp). the 10 Points of Vigilance on Responsible Product Communication and on Advertising Law. There may be specific advertising and communication policies that apply to your activity or in your entity. Contact your Chief Marketing Officer, Communication Director or Scientific Director for more details. 19  Al l n e w syst e m s ar e PROMOTING RESPONSIBLE USAGE OF TECHNOLOGY Over the past few years, L’Oréal has become a digital-first company. We leverage ass e ss e d f r om a INTRODUCTION the power of technology to create a beauty that is more inclusive, responsible, s e c ur it y , data a n d pr ivac y pe r spe ct iv e ETHICAL PRINCIPLES sustainable and transparent for our consumers, but also for our communities and the HUMAN RIGHTS planet. As a leader in the beauty industry, we aim to pave the way for the responsible t o s e c ur e t h e SPEAK UP development and use of digital marketing and Beauty Tech devices and services. AS A BUSINESS WE WILL WE WILL NOT int e g r it y o f t h e AS AN EMPLOYER  ct fairly and in accordance with our Ethical A  ompromise on the safety or quality C in for m at io n.​ Principles when making decisions or using solutions of our devices and services. based on AI algorithms in order to avoid unfair bias. AS A RESPONSIBLE  ssess and act on the environmental A  ver rely on algorithmic decision-making O without safeguards and human oversight. - C amilo, CORPORATION footprint of our tech environment.  iolate human rights, notably privacy V Beaut y t ec h Promote inclusive tech initiatives. rights, nor cause restriction on individuals’ CONTACT freedom of choice when using AI systems. 20  FAQs From an ethical point of view, how We use technology and digital services, can we ensure in our AI development while at the same time commit to limit that we do not take things too far? the impact of our activities on carbon INTRODUCTION emissions. How can we do both? AI offers many opportunities but also ETHICAL PRINCIPLES HUMAN RIGHTS raises many questions that we must address. These are not easy questions This is a challenging question. This is why we have built a dedicated sustainable E thics in action SPEAK UP and we will adapt as we learn more. IT & Tech roadmap whose objective is As part of our Principles for Trustworthy AI, In collaboration with the Global Ethics to make sure that the environmental department, we have defined our impact of our Tech is under control, L’Oréal sets up internal operational processes AS A BUSINESS Responsible Framework for AI to ensure and that we leverage tech to reduce and development milestones. we develop and acquire AI systems the impact of our business. As an that are trustworthy and respectful illustration, we all have a role to play AS AN EMPLOYER of all our users. We will implement in limiting the environmental footprint a programme based on three steps: of the usage of technology daily, by Principles for Trustworthy AI, Training applying the digital tips. We work as AS A RESPONSIBLE & recruitment and Review & monitoring. well on Sustainable Tech by design to CORPORATION limit the impact of our tech initiatives. Our brand developed a tool that identifies a consumer’s skin concerns CONTACT and allows us to recommend personalised products. However, as the tool does not perform as well for certain specific skin tones, we plan on offering this service only to specific consumers. Is this possible? We need to ensure we do not discriminate against our consumers How can you act ? in the access to our products and services. In this case, you should Read our Principles for Trustworthy AI. not put on the market a tool that There may be specific policies that apply to your does not serve all consumers. activity or in your entity. Contact your Digital or Beauty Tech teams for more details. 21  Em pl oy e e s s har e wit h HANDLING PERSONAL DATA WITH CARE us their per sonal data , and we We have a responsibility to uphold everyone’s right to privacy. The way we collect, store and INTRODUCTION use personal data is an important factor in maintaining the trust of our stakeholders. ETHICAL PRINCIPLES absolut ely need to pr ot ect them whilst HUMAN RIGHTS SPEAK UP WE WILL WE WILL NOT AS A BUSINESS  ake sure the people from whom we collect M personal data are informed of the type of  ollect sensitive information unless we C are legally obliged to do so or with the cr eating bet t er information we are collecting, how we plan to use it, who we may share it with and who consent of the person concerned. ser vices. AS AN EMPLOYER they can contact if they have any questions.  se personal data in ways not U explained in advance to the person - L a ur e n t ,  nly collect the personal data that is necessary O from whom we collected the data. AS A RESPONSIBLE CORPORATION and ensure that it is securely processed.  eep personal data longer than is K HR Data &  ake into account the possible impacts T necessary to meet the legal or business A n a l y t ic s ​ of our use of new technologies. need for which it was collected. CONTACT  nsure that all third parties from whom E  ake decisions based solely on automated M we obtain personal data or who collect, processing when this can significantly store or use personal data on our behalf, impact the people concerned. share our data privacy standards.  ake action or Speak Up if we become T aware of any data privacy issue. 22  FAQs What do we mean by I hear that there is money to be sensitive information and made from selling data to other why do we need to use it? companies. Do we do this at L’Oréal? INTRODUCTION This includes any information related We only collect personal data for our own ETHICAL PRINCIPLES HUMAN RIGHTS to biometric data (e.g. retina or iris scan, fingerprint, voiceprint, or scan of business or research purposes. We do not sell personal data we collect. We E thics in action SPEAK UP hand or face geometry), health data, sometimes share data with third parties, L’Oréal wishes to promote the responsible use genetic data, ethnic origin, political for example when helping a university opinions, religious or philosophical on a research project, but in such cases of AI, notably to avoid algorithmic bias. AS A BUSINESS beliefs, trade-union membership, data the data is always anonymised. concerning an individual’s sex life or sexual orientation. We rarely process Is it true that HR and IT can AS AN EMPLOYER this type of data except when there is review all my emails and files? a legal obligation or for the purpose In principle, we can only use the of clinical or evaluation studies with AS A RESPONSIBLE equipment put at our disposal volunteers who test our products. CORPORATION for professional reasons. When we join L’Oréal, we are made aware of all workplace monitoring and its CONTACT purpose. Employees’ emails and files are only accessed when L’Oréal has a legitimate business reason. There are very strict rules on when personal information is subject to review. How can you act ? Read the Data Privacy 10 Points of Vigilance in the Fundamentals of Internal Control, the Digital Technology User Charter, our Principles for Trustworthy AI, Group Human Rights policy and Employee Human Rights policy. There may be specific policies on data privacy that apply to your activity or in your entity. Contact your local Data Privacy Officer for more details. 23  PROTECTING CONFIDENTIAL INFORMATION We must protect the confidential information of L’Oréal and our business partners. Disclosing E thics in action INTRODUCTION such information could not only harm our reputation but also affect our stakeholders’ trust. All L’Oréal employees are required to follow specific ETHICAL PRINCIPLES training on how to ensure information is kept safe. HUMAN RIGHTS SPEAK UP WE WILL WE WILL NOT  espect the Group’s rules on information R  iscuss or work with confidential information D AS A BUSINESS protection, use of digital technology and in a public area where conversations can insider trading which aim to limit the be overheard or data compromised. AS AN EMPLOYER disclosure of non-public information to people with a legitimate ‘need to know’.  isclose a previous employer’s D How can you act ? confidential information. Immediately inform our manager if we Read our ethical guides The Way We Work with Start- AS A RESPONSIBLE have inadvertently disclosed confidential  eep any confidential information K Ups, The Way We Work with our Suppliers regarding CORPORATION information or if we discover that confidential when leaving L’Oréal. our relationship with suppliers and The Way We information has been disclosed. Compete on our relationship with competitors and clients, our Information Security policy and Social Media CONTACT  e careful not to disclose confidential information B policy as well as our Stock Market Code of Ethics. when third parties are present (i.e. visiting There may be specific policies on confidential information our premises, when we are travelling, etc.). that apply to your activity or in your entity. Contact your manager or Ethics Correspondent for more details. FAQs How can we balance transparency Sometimes we need to ask for confidential At L’Oréal, we love to chat in corridors, while having a with business confidentiality? information from third parties, for example coffee etc. Can we really avoid visitors from hearing Being transparent does not mean that we should be start-ups. How can we make sure they trust us? something they should not without becoming paranoid? an open book. We have a legitimate reason to protect Showing that we know how to handle confidential The easiest way to avoid this is to use designated meeting certain information. It’s mostly a question of mindset. information is key to building trust. Only ask for rooms for meetings with visitors or to warn your colleagues We should systematically ask ourselves if we can be the information you really need, explain why if you are expecting to take a visitor to your office. Again, more transparent but also recognise that it is our duty you need it, what information you will give in if confidential information is leaked, we all suffer. to protect confidential information. In case of any return, how you will use this information and doubt, ask your manager or Communication Director. with whom and how you will keep it safe. 24  BUILDING STRONG RELATIONSHIPS WITH OUR BUSINESS PARTNERS INTRODUCTION We want to build a sustainable ecosystem with our business partners based ETHICAL PRINCIPLES on trust and mutual benefit. We are committed to having transparent and HUMAN RIGHTS fair selection criteria and to giving honest and respectful feedback. We also SPEAK UP seek and support business partners who share our ethical standards. AS A BUSINESS WE WILL WE WILL NOT  espect our commitments to our business R Impose abusive conditions on business AS AN EMPLOYER partners (for example paying suppliers or delivering partners (namely in terms of payment, to clients on time) and be open and diligent deadlines, changing orders etc.). AS A RESPONSIBLE if we face any difficulties in doing so or if there CORPORATION are any legitimate reasons for not doing so.  sk our business partners to do what A we are not able or willing to do ourselves.  how understanding when our business partners S CONTACT encounter difficulties, particularly in times of crisis.  void our business partners being overly A economically dependent on L’Oréal business.  xplain our ethical expectations and support E business partners in meeting them while W e c o n d u ct h u n dr e ds having the courage to end relationships with those who are unwilling to meet them. o f a u d it s e v e r y y e a r to p a r t n e r w it h t h e r ig h t s u p p l ie r s , w h o ad h e r e t o o u r e t h ic a l sta n dar ds.