Code of Ethics

The way we work

3rd Edition
CONTENTS

3 THE L’ORÉAL SPIRIT 21 Representing the Company

4 Forewords 22 Privacy and data protection

by Jean-Paul Agon
by Emmanuel Lulin 24 Use of Company resources

5 by the Executive Committee 25 Financial and business records

and the fight against money laundering
6 Who does this Code apply to?
26 Insider trading
6 How to use this Code
27 Tax
7 I HAVE A CONCERN: OPEN TALK

8 Working together 28 RESPECTING OUR COMMITMENTS

AS AN EMPLOYER
8 Respecting human rights
29 Health, safety and security
8 Respecting local laws and customs
30 Diversity

9 RESPECTING OUR COMMITMENTS 32 Harassment and bullying

AS A BUSINESS
33 Sexual harassment
10 Product safety and quality

11 Advertising and marketing

34 RESPECTING OUR COMMITMENTS
13 Supplier selection and fair treatment of suppliers AS A RESPONSIBLE CORPORATE CITIZEN

14 Fair competition 35 Political activities and lobbying

16 Conflicts of interests 36 Environmental stewardship

18 Gifts and entertainment 37 Contribution to the community

19 Bribery and facilitation payments

20 Confidential information 38 THE MANAGER’S ROLE

2
 THE L’ORÉAL SPIRIT
L’ORÉAL has set itself the mission of offering all women and men worldwide the best of cosmetics innovation
in terms of quality, efficacy and safety. Our ambition for the coming years is to win over another one billion
consumers around the world by creating the cosmetic products that meet the infinite diversity of their beauty
needs and desires. Our identity and reputation are based on strong Values and Ethical Principles. Our Values
are Passion, Innovation, Entrepreneurial Spirit, Open-Mindedness, Quest for Excellence and Responsibility.
Our Ethical Principles are Integrity, Respect, Courage and Transparency.

AS A BUSINESS
Our strategy for leadership is based on continuous investment in our research and development. This enables
our brands to deliver to our consumers products that are innovative, highly effective, practical and pleasant to
use, and which are manufactured to the most demanding standards of quality and safety. We place great value
on honesty and clarity: our consumer advertising is based on proven performance and by scientific data. We are
committed to building strong and lasting relationships with our customers and our suppliers, founded on trust
and mutual benefit. We respect the stakeholders of our business environment, including our competitors. We do
business with integrity: we respect the laws of the countries in which we operate and adhere to good corporate
governance practices. We maintain high standards in accounting and reporting, and support the fight against
corruption. We deliver long-term, sustained shareholder value by protecting and making the most effective use
of Company assets. We aim for excellence, and constantly challenge ourselves and our methods.

AS AN EMPLOYER
We aim to make L’ORÉAL a great place in which to work. We know that our employees are our greatest assets. They
are entitled to a safe and healthy working environment: one in which personal talent and merit are recognised,
diversity is valued, privacy is respected, and the balance between professional and personal life is taken into
account. We believe in offering our employees a stimulating environment, exciting personal opportunities and
a chance to make a difference. We encourage an atmosphere of openness, courage, generosity and respect, so
that all our employees feel free to come forward with their questions, ideas and concerns.

AS A RESPONSIBLE CORPORATE CITIZEN

We play our part in creating a world of beauty and fairness. We are mindful of our impact on the natural
environment, including biodiversity, and constantly seek to reduce it: we are determined to avoid compromising
tomorrow for the sake of today. We make a positive contribution to the countries and communities in which
we are present, and respect local cultures and sensitivities. We are committed to the respect of Human Rights.
We want to help end the exploitation of children in the workplace and the use of forced labour. We want an end
to animal testing in our industry, and we contribute to the development and acceptance of alternative methods.
We actively seek out and favour business partners who share our values and our ethical commitments.

This is the spirit in which we operate: The L’ORÉAL SPIRIT

3
FOREWORDS
BY JEAN-PAUL AGON

In the 21st century, only companies that have integrated ethics in their culture,
strategy and day-to-day practices will be sustainable.

Our ambition is to be one of the most exemplary companies worldwide. Our ethics
program is already recognized and places us amongst the world’s leading companies
in this field.

Our strong ethical culture is one of the pillars of the New L’ORÉAL. This is why we
must clearly state our commitments as a business, as an employer and as a corporate
citizen.

Our Ethical Principles - Integrity, Respect, Courage and Transparency – will allow us
to continue be a Group which inspires trust.

The Code of Ethics applies to all of us, wherever we work and whatever our job – whether we are a new employee,
a Management Committee member, and up to the Board of Directors.

The Code of Ethics is our reference document, to inspire our choices and to guide our day-to-day actions.

Read this Code carefully. Live it. Pass it on. Respect it and make sure it is respected around you.

L’ORÉAL needs everyone’s exemplarity to be exemplary.

JEAN-PAUL AGON
Chairman and Chief Executive Officer
Chairman of the L’ORÉAL Foundation

BY EMMANUEL LULIN

Our Code of Ethics is a living and shared document that covers subjects that are essential to our culture of
loyalty, trust and solidarity. It aims to help us understand what is expected of us as L’ORÉAL employees, by
setting out the general principles and through numerous practical day-to-day examples.

Beyond this document, you have at your disposal a dedicated intranet site (http://
ethics.loreal.wans) and trainings. Ethics Correspondents in each Country help us to
live our Code.

Ethics however is an essential duty of each and every one of us.

For many years, we have also come together during Ethics Day. More and more of
you participate in this event which has become a key date in the Group’s calendar.

All employees and entities must work together in a respectful and open manner.
Credit must be given to other people’s ideas. We should listen with generosity and
share information as needed, subject to our rules on confidentiality.

Ethical issues are rarely simple. Our strength is to have the courage to address them. Do not keep these questions
for yourselves: speak up and ask for advice.

You will always be supported in this process.

EMMANUEL LULIN
Senior Vice-President and Chief Ethics Officer

4
 The way we work

BY THE EXECUTIVE COMMITTEE

We are committed to live out the

Code of Ethics in our day to day work.
It is crucially important to L’ORÉAL’s 2
3
5
7
8 1 9 10 11
15
16
13
success. 4
12 14
6
Ethics applies to the behaviour
of all L’ORÉAL Group employees,
everywhere in the world, at all levels
of the Company, without exception.
It covers all L’ORÉAL’s activities, from
research, innovation and design of our
products to their manufacturing and
1 - JEAN-PAUL AGON 6 - SARA RAVELLA 11 - ALEXANDRE POPOFF
marketing, from human resources to Chairman and CEO Executive Vice-President Executive Vice-President
our operations, from administration Chairman of the L’ORÉAL Communication, Eastern Europe Zone
and finance to sustainable Foundation Sustainability and Public
development, from communication Affairs
and public affairs to digital.
12 - BRIGITTE LIBERMAN
2 - BARBARA LAVERNOS President Active Cosmetics
Each of us, as an ambassador and Executive Vice-President 7 - MARC MENESGUEN Division
member of the L’ORÉAL community, Operations President Consumer
makes a personal commitment to Products Division
follow this Code, both in letter and
spirit. 3 - JOCHEN ZAUMSEIL 13 - GEOFF SKINGSLEY
Executive Vice-President Executive Vice-President
8 - NICOLAS HIERONIMUS
You should always remember that: Western Europe Zone Africa, Middle East Zone
President Selective
Divisions
• t he ethical principles set out in
this document are not optional: 4 - ALEXIS PERAKIS-VALAT 14 - LUBOMIRA ROCHET
you must respect them Executive Vice-President Chief Digital Officer
9 - CHRISTIAN MULLIEZ
•y  ou set the example: L’ORÉAL’s Asia-Pacific Zone Executive Vice-President
reputation, the trust of all our Administration and Finance
stakeholders, depend on each of us 15 - FRÉDÉRIC ROZÉ
• you will be evaluated not only on 5 - JÉRÔME TIXIER Executive Vice-President
what you do but also on how you Executive Vice-President Americas Zone
10 - LAURENT ATTAL
do it Human Relations and Executive Vice-President
Advisor to the Chairman Research and Innovation
16 - AN VERHULST-SANTOS
President Professional
Products Division

5
WHO DOES
THIS CODE APPLY TO?

The Code of Ethics applies to all employees of the Foundation. In order to allow as many employees as
L’ORÉAL Group and its subsidiaries worldwide. It possible to read the Code of Ethics in their mother
also applies to all corporate officers and members tongue, the Code of Ethics is currently available in
of the Executive and Management Committees of 45 translations. The UK English version of this Code
the L’ORÉAL Group and its subsidiaries worldwide. is the reference document.
Moreover, the Code of Ethics applies to all employees
and corporate officers of the L’ORÉAL Foundation. The Code of Ethics is publically available on
The term “L’ORÉAL” used in this document refers to L’ORÉAL’s corporate website.
all subsidiaries of the L’ORÉAL Group and L’ORÉAL

HOW
TO USE THIS CODE

L’ORÉAL operates in many countries – home to a If the answer to one of these questions is no, or if
wide variety of cultures, laws and political systems. you have any doubts, the golden rule is to consult
the appropriate people (your management, internal
We as a business and as individuals in the experts, Ethics Correspondent, etc.) and discuss
performance of our duties must always respect the matter openly before acting (see also “I Have
the laws and regulations of the countries in which a Concern: Open Talk”).
L’ORÉAL operates.
The Code of Ethics does not replace any existing
We recognise that some situations are not easy. policies, and you should continue to refer to whatever
Ethics is often about arbitrating a conflict of rules and standards have been set in your workplace.
principles. Our Code of Ethics sets standards for the This Code aims to provide a framework for these
Group in a number of “grey areas”, where, beyond the policies and standards, so that it is easier for you to
law, a discretionary decision is required. understand the rationale behind them.

Read all of the Code to learn about L’ORÉAL’s ethical L’ORÉAL acknowledges that the Code of Ethics is
expectations and standards, and then keep a copy not exhaustive and that its content may change from
for yourself for future reference should you have any time to time.
questions or concerns.
L’ORÉAL reserves the right to change the Code of
Of course, no document can anticipate and address Ethics at any time, with or without notice, and the
every situation that may arise. So whenever you are right to take whatever action it deems appropriate
faced with this type of decision, ask yourself the in a given situation, subject to not contravening
following questions: L’ORÉAL’s Ethical Principles.

1. Is it in line with the Code of Ethics?

2. Is it legal?

3. I s it in line with our Ethical Principles of Integrity,

Respect, Courage and Transparency?

4. H
 ow would my actions affect our stakeholders and
could I justify my decision?

5. W
 ould I be comfortable if my decision was made
public internally or externally?

6
 The way we work

I HAVE
A CONCERN

L’ORÉAL encourages a culture of openness where “Good faith” means that you have provided
employees can raise their genuine concerns. information that you believe to be comprehensive,
honest and accurate at the time, even if you are later
We encourage all employees to express their views, proven to be mistaken.
defend their opinions and point out unacceptable
behaviours and demands. We will ensure a fair process in the case of
an investigation, respecting the principles
Employees may have concerns about certain of confidentiality and presumption of innocence.
practices and need advice and guidance to help Any investigation will also comply with applicable
resolve them. It is our policy that all reports of local legislation, especially regarding due process.
misconduct on the part of the Company, one of
its employees or even a third party with which the During an ethical investigation, the full cooperation of
Company is in contact are thoroughly investigated, everyone involved is mandatory and all information
and that appropriate actions are taken, regardless of and documents must be immediately provided upon
the people involved. first request.

The normal route for raising such issues is via your The person implicated will be informed of the
operational or functional management. You can also nature of the allegations made against him/her.
contact your Human Resources Manager or your The information may not be provided immediately
Ethics Correspondent. There may also be additional should it prove necessary, for example, to check the
resources available in your country, such as staff facts, preserve evidence or contact the competent
representatives. authorities.

Your Country Manager or, for Corporate or Zone All information communicated will be shared only
staff, the member of the Group’s Executive with those persons who have a legitimate reason to
Committee to which you report, is responsible know either to ensure the concern is handled and/or
for ensuring the respect of the Code of Ethics; the appropriate steps are taken.
if necessary, you can contact him or her.
We will provide the results of the investigation to
In exceptional cases, if your concern cannot be the individual who has raised the concern to the
handled through normal channels, you can directly extent that it is appropriate and can be given without
contact the Chief Ethics Officer via the secure Web infringing legal requirements or other duties of
site: www.lorealethics.com confidentiality.

Any employee raising such concerns in good faith Any accusations that prove to be slanderous or made
will be protected against retaliation. Any employee in bad faith may result in disciplinary proceedings.
who believes he/she is being retaliated against must
immediately report this by the same channels as
indicated above.

7
WORKING
TOGETHER

We expect all employees and entities to work Lack of respect, in particular through abusive speech
together in a respectful and open manner. or inappropriate gestures or racist, discriminatory
or sexual remarks, is unacceptable. Disparagement
Teamwork is encouraged and successes, as well as of colleagues is also contrary to L’ORÉAL’s ethics.
failures, should be shared.
In this way, we will maintain a culture of loyalty,
We should all aim to give credit to other people’s trust, solidarity and respect for cultural differences
ideas, and recognise the contributions of others. throughout our business.
We should listen with generosity and share
information as needed, subject to the Group’s rules
on confidentiality.

RESPECTING
HUMAN RIGHTS

We are committed to respecting and promoting We are present in many countries, and we are
Human Rights, namely by reference to the Universal particularly vigilant on issues covered by the
Declaration of Human Rights dated December 10, Fundamental Conventions of the International Labour
1948, and the United Nations Guiding Principles on Organization (prohibition of child labour and forced
Business and Human Rights dated June 16, 2011. labour, respect of freedom of association), promotion
We have been a signatory to the United Nations of diversity, women’s rights, respect for the rights
Global Compact since 2003 and we support the UN of people to use their natural resources and the right
Women’s Empowerment Principles. to health.

RESPECTING
LOCAL LAWS AND CUSTOMS

L’ORÉAL is particularly attached to the spirit and the There may be instances when the guidance in this
letter of laws governing quality, health and safety Code is at variance with the local law or customs of
standards, labour law, the environment, corruption a particular country. If that is the case, where local
and money-laundering, data privacy, taxation, law or customs impose higher standards than those
accurate communication of financial and non- set out in the Code, local law and customs should
financial information and fair competition. always apply. If, by contrast, the Code provides for a
higher standard, it should prevail, unless this results
L’ORÉAL seeks to share these principles with its in illegal activity.
business partners and to ensure that such partners
also respect these laws and regulations.

We should also ensure, wherever possible, that we

conduct our activities in a manner that is sensitive to
the cultural and social traditions of communities with
which we come into contact.

8
 The way we work

RESPECTING OUR COMMITMENTS AS A BUSINESS

“We aim for excellence, and constantly

challenge ourselves and our methods.”

Table of contents
PAG E 1 0 PAG E 1 8 PAG E 2 4
Product safety and Gifts and entertainment Use of Company
quality resources
PAG E 1 9
PAG E 1 1 Bribery and facilitation PAG E 2 5
Advertising and payments Financial and business
marketing records and the fight
PAG E 2 0 against money laundering
PAG E 1 3 Confidential information
Supplier selection and PAG E 2 6
fair treatment of suppliers PAG E 2 1 Insider trading
Representing
PAG E 1 4 the Company PAG E 2 7
Fair competition Tax
PAG E 2 2
PAG E 1 6 Privacy and data
Conflicts of interests protection

9
As a business

PRODUCT
SAFETY & QUALITY
Product safety and quality has always been paramount at all times.
It is the superior performance, quality and safety of our products that demonstrate our dedication and respect
for our consumers, that maintain their trust, underpin the reputation of our brands and ensure that L’ORÉAL
remains the leader in our field.
We are committed to marketing products that have proven efficacy and safety, guaranteed by rigorous
evaluation methods. Every L’ORÉAL employee involved in product development, manufacturing, marketing
and sales must seek to achieve total product quality, from its conception to its distribution, even after it has
been put on the market.

We must 1.2 - We have received a report from a supplier

stating that contamination may have occurred in
+C
 omply with all national and international legislative a recent shipment of raw materials. The products
and regulatory requirements to ensure the containing these raw materials have already been
conformity of all our products shipped to our customer and there is no concrete
evidence of contamination in our products. Do we
+E
 nsure that the highest standards of hygiene and have an obligation to recall the entire production run?
strict quality controls are applied at each stage,
from product development to manufacturing and At L’ORÉAL, we respond promptly to any concern
distribution process about possible product safety. You should discuss
the issue with your manager or your Quality Control
+ If we know of a claim from a consumer, ask him Manager immediately.
or her to contact the appropriate Consumer
Department and when this claim appears to
be a potential health or safety concern, ensure 1.3 - I was just contacted by a consumer who had the
we immediately inform our manager or the wrong telephone number. He told me that he had had
International Cosmeto-Vigilance Department an allergic reaction after using one of our products.
What should I do?

We must not Give this consumer the number of the appropriate

consumer helpline and encourage him to contact them
-L
 imit a free and open exchange of views on product immediately. As well, send this information yourself
safety so that no safety issue is ignored to the International Cosmeto-Vigilance Department.
At L’ORÉAL, after a detailed study of the eventual
- Ignore any potential concerns about product safety, causal relationship with our products, we sometimes
tolerance and quality control issues can decide to adjust the composition of a product to
correct some undesired effects, even if very mild, in
-A
 nswer media questions (including those from order to guarantee to our consumers that they can use
social media) on our products if we are not our products with the fullest confidence.
competent and authorised to do so

1.4 - I am often asked by my family and friends about

Ethical? our position on animal testing… I don’t know what to
tell them. Whom should I approach about this?
1.1 - I work on the production line. I’ve noticed
some defective finished goods. A machine may be L’ORÉAL no longer tests on animals any of its products
generating some quality problems. I know we’re or any of its ingredients, anywhere in the world.
supposed to stop production when that happens, but Nor does L’ORÉAL delegate this task to others. An
my supervisor has not taken any action. I know that exception could only be made if regulatory authorities
the production schedule is very tight. Should I trust demanded it for safety or regulatory purposes. If you
that she knows what she’s doing in ignoring it? have any questions on this subject, you can contact
your Public Relations Director. Remember: you should
L’ORÉAL has put in place quality controls at each be careful when speaking on topics outside your area
stage of the manufacturing process to ensure that our of expertise (see the chapter on “Representing the
customers obtain the highest quality products. Quality Company”).
comes first, regardless of production schedules. You
should put that line on hold without any hesitation,
openly share the problem with your manager, and work
with her and the rest of the team to fix the issue, before
carrying on with production. Who to contact: If you have a concern about
product quality and/or safety, don’t keep it to
yourself. Speak to your manager, your Quality
Control Manager, your Legal Director, your
Scientific Director, your Human Resources
Manager or your Ethics Correspondent;
they will be able to help and support you (see also
the chapter on “I Have a Concern: Open Talk”).

10
 The way we work

ADVERTISING
& MARKETING
The success of our products is based on their intrinsic characteristics and performance. This principle is
essential to winning and keeping consumer trust and loyalty. We want to communicate responsibly by
respecting the infinite diversity of beauty needs and desires in the world. We do not promote a single or
unattainable model of beauty.

We must We must not

+F
 ollow internal validation processes for advertising -S
 eek to exploit the gullibility, lack of knowledge or
and claims even if it delays a product launch lack of experience of consumers

+E
 nsure that all advertising and promotional -A
 ssert in our advertising that the use of our
material is based on proven performance and products will confer a substantial professional or
relevant scientific data obtained during evaluations, social advantage or that our products are necessary
consumer or laboratory studies carried out in for overcoming personal problems or being socially
accordance with our industry’s best practices accepted

+G
 ive a fair, precise and truthful description of our -U
 ndermine human dignity in our advertising or
products and their effects present degrading stereotypes

+C
 learly express the purpose and correct usage -A
 dvertise in certain media or around programmes
of our products and take care that it is readily whose appeal strategy is based on violence, sex,
understood by consumers superstition or the incitement of hatred toward
anyone. Such strategies are contrary to L’ORÉAL’s
+E
 nsure that our brands promote the largest number Ethical Principles
of beauty types
-H
 ave children appear in advertising for a product
+B
 e sensitive to the possible reaction of religious, that has not been tested for use on children unless it
ethnic, cultural or social groups to our advertising is clear in the advertisement that the product is not
intended for children
+T
 ake great care to ensure our actions are consistent
with our Ethical Principles if we are promoting -S
 pecifically target very young children in our
products for children and young people advertising and promotions, except for sunscreen
and hygiene products
+B
 e especially vigilant regarding the working
conditions of the children who may appear in our -D
 eliberately exaggerate claims in our
advertising communications, including environmental
or societal claims
+T
 ake care when using animals in our advertising; in
particular not have recourse to threatened species -C
 ollect information for behavioural marketing
or animals whose training conditions are clearly purposes without first informing Internet users
unacceptable (e.g., using cookies)

+D
 esign our sales promotions and direct marketing
operations so that consumers can easily understand
the conditions of the offer

+P
 rotect our consumers’ personal data (see the
chapter on Privacy and Data Protection)

+R
 efrain from making disparaging remarks
concerning competitors (including any false
statements concerning their products or services)

11
As a business

Ethical? 2.4 - I would like to include in an advertisement

the fact that a product does not contain
2.1 - My colleague has shown me a marketing hexachlorophene, which is not surprising since the
proposal for a body lotion that uses an extremely use of this ingredient is prohibited by law. However,
thin young model. I think it’s distasteful in the least, it sounds good to consumers. But I have colleagues
and could lead us to accusations of encouraging girls who think that it is a borderline claim. Who is right?
to starve themselves in pursuit of an unhealthily thin
physique. She said I was being over-sensitive and that We cannot lead people to believe that our products
the artwork had already been approved. What can I have a specific property when this property comes
do about it? from simply respecting the law. It would be misleading
for our consumers. Your colleagues are right.
Our advertising and promotion is designed to
have the maximum impact possible on our desired
audience. We must therefore take responsibility for 2.5 - I am currently working on an advertisement
all the messages it communicates - or is seen to that takes place in a religious setting. The consumers
communicate. There is growing concern about eating targeted by this advertisement will probably like its
disorders among young women, and the health risks provocative style, and in my country, I don’t think
associated with this. This has to be taken into account it will offend anyone. However, I have a foreign
when deciding on our advertising campaigns. We do colleague who finds it a bit borderline. What should
not knowingly work with models who are under the I do?
age of 16 years except for specific advertising such as
sunscreen for children, or models who clearly appear We should evaluate our advertisements not only from
to have a serious eating disorder. We also avoid any our target consumers’ point of view, but also from the
advertising that promotes drugs, alcohol or smoking. view of society overall. Our adverts are viewed by many
You should encourage your colleague to get a second more people than only our targeted market. We must
opinion. You can also raise it with your manager. also take into account our international presence and
not use themes that could be considered acceptable
in one country, but extremely shocking in another
2.2 - In an advertisement for a hair styling product, country in which we operate. Lastly, we should not use
the model is going to wear a natural hair wig, and images, symbols or themes that could be considered
we will also photoshop her picture because her skin gratuitously offensive, demeaning or disrespectful of a
has blemishes. Is it acceptable when it comes to the religion, nationality, culture, minority group or disability.
sincerity of our claims? The best thing would be to obtain an objective
opinion, specifically via a panel before validating
Some retouching is necessary at times from a technical this advertisement and to pay attention to how this
perspective, but they should not at all be misleading as advertisement is disseminated.
to the performance of the product being advertised.
Using a natural hair wig is acceptable because it is an
advertisement for a styling product and is not related 2.6 - A famous brand of children’s clothing is
to hair volume. It is important that the wig used is made launching a line of dresses for little girls and wants
of real hair and coloured or styled with the products to buy lip gloss to offer them to their customers if
being advertised. Beware however of the origin of the they purchase over a certain amount. This is a good
natural hair used to make wigs, which can sometimes opportunity, right?
be controversial.
There is a growing debate about the early sexualisation
of young children. Although young children have
2.3 - I’m just devising a marketing programme always wanted to imitate adults, especially by playing
for a new product. The R&I department manager dress up with make-up and perfume, we believe that
has said that it only “reduces wrinkles”, but my it must remain a game, and, for that reason, we should
manager has told me to say it “eliminates wrinkles”. not encourage the daily use of cosmetics in young
I’m concerned that this isn’t entirely truthful. What people except for hygiene and sunscreen products.
should I do? Therefore, it is best to avoid associating our brands with
objects, themes or events aimed at young children. For
We act in line with both the Consolidated Code of the example, we do not supply products for “Mini-Miss”
International Chamber of Commerce on Advertising type contests.
and Business Communication Practices, and also
the Charter and Guiding Principles on Responsible
Advertising and Marketing Communication of Cosmetics
Europe. Overselling our products by making inflated
or exaggerated claims for them is dishonest, creates Who to contact: If you have a concern about
distrust among our customer base and could be advertising or marketing, don’t keep it to yourself.
considered misleading. If the product does not eliminate Speak to your manager, your Legal Director,
wrinkles, then you should not claim that it does. your Human Resources Manager or your Ethics
Correspondent; they will be able to help and
support you (see also the chapter on “I Have a
Concern: Open Talk”).

12
 The way we work

SUPPLIER SELECTION
& FAIR TREATMENT OF SUPPLIERS
L’ORÉAL’s relationship with its suppliers extends beyond the purchase and delivery of goods and services.
It is integral to the long-term success of our business. We will be judged by the quality of the relationship
we have with our suppliers. In particular, we will be scrutinised on how we select our suppliers, and how they
demonstrate their commitment to doing business responsibly. We are proud of our reputation for dealing
with suppliers in a mutually supportive and open way. These relationships are based on the principles of
impartiality, fairness and loyalty and we respect their independence and identity. L’ORÉAL will not abuse its
market position in order to gain preferential treatment.

We must You can tell the first supplier in very broad terms
that you have a better price elsewhere, but without
+S
 elect suppliers on the basis of open competitive revealing the identity and price of the second supplier.
bidding; ensure that all supplier offers are Otherwise, you would be giving the first supplier
compared and considered fairly and without confidential information about his competitor, which is
favouritism unethical, and, in many countries, against the law.

+B
 e transparent about the bidding process and give
honest, sensitive feedback to failed bids based on 3.2 - I have found a really good supplier but he is
objective elements just starting up his business and L’ORÉAL is, for the
moment, his only client. Can I use him?
+ Ensure
 that our ethical expectations are understood
and respected by all suppliers wherever they Yes. There is no reason not to help this supplier start his
operate business. However, you should enter into a temporary
contract and inform the supplier that he is expected to
+ Support
 suppliers in meeting L’ORÉAL’s find other customers before a certain period of time. If
expectations he really is good, this should not be a problem. If at the
end of your contract, he has not done so, you should
+ Pay
 suppliers on time and according to the agreed consider changing suppliers.
terms, unless there are legitimate reasons for not
doing so, such as merchandise ordered not being
delivered 3.3 - Someone told me confidentially that one of our
overseas suppliers is under investigation following
+M
 ake sure that our suppliers are not overly allegations of forced labour. The supplier hasn’t told
economically dependent on L’ORÉAL business me any of this, and on previous site visits there’s been
no reason for concern. Should I ignore these rumours?
+P
 rotect the suppliers’ confidential information as
though it were our own No. You should investigate, starting by asking the
supplier for information. If you are in any doubt,
consider including them in L’ORÉAL’s Social Audit
We must not programme, which involves sending an external auditor
to verify the facts around employment practices,
- Impose abusive conditions on suppliers (namely in working conditions and other issues. If the audit reveals
terms of payment, deadlines…) scope for improvement, we will inform the supplier
and try to get him to agree to a corrective action
-C
 ontinue to work with a supplier who is repeatedly plan. Of course, in case of severe non-compliance
not meeting L’ORÉAL’s expectations or not with our standards which we do not think we can fix
respecting our Ethical Principles, namely with immediately or if the supplier does not improve, we
regards Human Rights and/or the fight against must end the relationship.
corruption
FOR MORE INFORMATION:
please read “The Way We Buy” and “Suppliers /
Subcontractors and Child Labour”.
Ethical?
3.1 - I am trying to find a new supplier for office
materials. The first one I contacted offers a good
service, but at a high price. The second isn’t quite as Who to contact: If you have a concern about
good, but he’s cheaper (mainly because he’s made supplier selection or treatment, don’t keep it to
a significant discount in an effort to win L’ORÉAL yourself. Speak to your manager, your Purchasing
business). Can I tell the first supplier what price the Manager, your Human Resources Manager or
second guy quoted, in order to try to get his price your Ethics Correspondent; they will be able to
down? help and support you (see also the chapter on
“I Have a Concern: Open Talk”).

13
As a business

FAIR
COMPETITION
We respect all stakeholders in our professional sphere, including competitors. We treat them the way we
would like them to treat us. Our position as leader in the cosmetics industry reinforces our duty to set a good
example in this area.
It is in our interest to work in an industry where business practices are reputable. It makes our work easier and
reinforces the trust of our customers. Sharing any type of information such as pricing, costs or marketing plans
with competitors can lead to the appearance of price fixing, territorial division or other types of manipulation
or distortion of the free market. In most countries, there are very strict laws in this area which we must be
aware of and comply with.

We must We do not share or exchange price or bid information

with competitors. This includes pricing policies,
+P
 romptly disclose to our management if we discounts, promotions, royalties, warranties and terms
have inadvertently received or used proprietary and conditions of sale. If a competitor volunteers
or confidential information which relates to such information, you should bring the conversation
competitors and legitimately belongs only to them to a close sensitively but immediately, and alert your
or to third parties management and the Legal Department. You should
of course also not share this information with anyone.
+R
 efrain from taking action to cut off a competitor’s While the exchange may be intended innocently, it
sources of supply or commercial outlets also could create the appearance of price-fixing or
bid-rigging which is unethical and, in most countries,
+ Never
 allow new recruits to L’ORÉAL to share illegal.
confidential information about competitors for
whom they used to work
4.2 - L’ORÉAL is a member of the National
+R
 efrain from all disparaging remarks concerning Professional Cosmetics Association and I am
competitors (including any false statements L’ORÉAL’s representative for the Commercial
concerning their products or services) Committee. After one of the Committee’s monthly
meetings, one of my colleagues, a representative of
a very well-known competitor, suggested that the
members of the Committee meet in a restaurant to
We must not reinforce personal links and to speak “off the record”.
What should I do?
-B
 e in contact with competitors where confidential
information is discussed Do not accept the invitation, and immediately inform
your Legal Department. We have the obligation to warn
- Induce
 customers or suppliers to breach contracts the Association of such “off-the-record” meetings.
with competitors Remember that contacts with competitors must remain
exceptional and limited to non-specific, non-sensitive,
- Establish
 exclusive dealing arrangements (i.e. non-strategic topics. Strictly avoid informal contacts
contracts that require a company to buy or sell only and even social events with competitors. If during
to L’ORÉAL) without prior legal advice “authorised” official contacts with competitors, you
realise that sensitive issues are about to be discussed,
-C
 ollect competitive information through illegal just leave the meeting and get the fact that you left
means and/or by failing to identify oneself clearly registered in the minutes.
as a L’ORÉAL employee when collecting such
information
4.3 - I’ve found out that one of our main competitors
- Impose
 contracts which tie or bundle together will be launching a new product shortly that could
different products or services (e.g., those which have serious implications for our sales and marketing
require a buyer who wants one product to buy strategies. We desperately need to find out more
a second “tied” product as well) or allow fidelity about it, whatever it takes. Given how crucial this is,
rebates without prior legal advice can we hire someone to sort through their trash in
search of clues as to their launch strategy?
- Influence the pricing policy of our clients
No. This is wholly unethical behaviour, which could
be severely damaging to our reputation for integrity.
L’ORÉAL can never be party to such activities. We can
Ethical? only collect competitive information through legitimate
means. Such means include examining our competitors’
4.1 - I ran into one of our competitor’s representatives products and using publicly available sources, such
at a trade show recently. Over a drink in the bar, he as promotional leaflets, annual reports, competitors’
mentioned that his company would soon implement displays at trade shows, and aggregated industry data
a price increase on several key products. This is really that does not disclose company-specific information.
useful intelligence! Who should I tell about it so we
can take full advantage?

14
 The way we work

4.4 - While visiting a client, he gave me information FOR MORE INFORMATION:

on my competitors’ recommended prices as well as please read “The Way We Compete”.
their launch plans. Can I also ask him for information
on the in-store set-up for these launches?

You should not collect non-public sensitive information

(prices, product launches, market shares, advertising Who to contact: If you have a concern about
budget, etc.) on our competitors whether directly competition, don’t keep it to yourself. Speak to
from our competitors or indirectly, namely through our your manager, your Legal Director, your Human
clients. Doing so poses a risk for both L’ORÉAL and the Resources Manager or your Ethics Correspondent;
client. they will be able to help and support you (see also
the chapter on “I Have a Concern: Open Talk”).

4.5 - Six months ago, I hired someone who used

to work for a competitor. While there, she gained
some hugely valuable research expertise in a really
key area for us. Indeed, that experience was one
of the main reasons I hired her. Obviously, I’ve
taken great care to ensure she doesn’t pass on any
confidential information to us, but surely there’s a
time limit, after which she can share her knowledge
freely? Otherwise, it would just be taking all this
confidentiality stuff to extremes, wouldn’t it?

No. There is no time limit on protecting confidential

information. Your recruit should have been hired on the
basis of her skills, and not because of her past work for
our competitor. It may even be appropriate to transfer
her to a different department, where she won’t feel
under any pressure or tempted to pass on confidential
knowledge.

15
As a business

CONFLICTS
OF INTERESTS
As a leader on the cosmetics market, we must be particularly attentive to conflicts of interests. We should all
avoid situations where our personal interests might come into conflict with the interests of L’ORÉAL. Even
the appearance of a conflict can tarnish L’ORÉAL’s reputation - as well as our own. The golden rule when
dealing with any conflict or even potential conflict is full disclosure of all the facts. That allows everything to
be properly examined.

We must 5.3 - My son owns a really good local hotel, and

lots of companies in the area use it for lunches and
+D
 isclose to our management if there is a potential functions. It would be an obvious choice for our
conflict of interests which might influence or event. Given that it compares well on price and
appear to influence our judgment and actions quality with other options, is there any obstacle to
(for example, where a family member is employed me making a booking?
by a supplier) or when we hold any position,
involvement or financial stake in any organisation Given the competitive price and popularity of the
that is a competitor, customer, supplier or any venue, it may well be acceptable for the Company
other business partner of L’ORÉAL, if our position to arrange functions there. However, it would not be
at L’ORÉAL allows us to influence the business right for you to have a say in the matter, as there is an
relationship obvious conflict of interests here. As with all such cases
where a close family member works for a current or
potential supplier or other business partner, you should
We must not disclose this fact to your manager. Then he or she can
take the necessary steps to avoid placing you in an
- Conceal any information on any conflict of interests awkward situation.

5.4 - During my spare time, I am Vice-President of the

Ethical? National Consumer Association. I’ve held this position
for many years. Now I’ve learnt the Association is
5.1 - One of my colleagues has a cousin who’s joined planning to lobby for a change in the law which might
us, and an old school friend of mine has just started cause problems for L’ORÉAL. What should I do?
working with me. I’m slightly concerned that people
might think there could be a conflict of interests here. L’ORÉAL respects employees’ privacy and takes a
Do these policies only apply to immediate family – or positive view on employees contributing to society
would they cover this, too? through associations or charities. However, you should
disclose your membership of or involvement in any
The answer is simple: if the relationship is such that such organisations to your management when you feel
it could influence your objectivity, then you should that there is a clash, or potential clash, with L’ORÉAL’s
apply this policy and ask for guidance. The fact that a interests. Your manager or Human Resources Manager
member of someone’s family or a friend already works will be able to guide you on appropriate action. In this
for L’ORÉAL has no bearing on their own worthiness case, you should also inform your colleagues in the
as a candidate for a job with the Company. But Association and withdraw from any involvement with
every effort must be made to ensure that salary and that particular lobbying campaign.
performance evaluation are handled by an independent
person, and that these situations are monitored on an
on-going basis to ensure objectivity and fairness to all. 5.5 - My wife works for one of L’ORÉAL’s competitors.
We don’t talk about work at home, and I can’t see it’s
any business of the Company what my wife does in
5.2 - I’ve been really impressed with the quality of her professional life. Yet some of my colleagues have
work from a particular L’ORÉAL supplier, and as a suggested I’m in a compromising situation. What
result I’d like to invest in the company. Is there any should I do?
conflict of interests here?
This could create the appearance of a conflict of
Even though your involvement could only be financial, interests. To protect both yourself and the Company,
there may be a conflict of interests depending on your you should disclose the facts to your management or
position in L’ORÉAL, your influence on purchasing Human Resources Manager. Additionally, you and your
decisions, the amount of your investment and the wife should take steps to ensure that confidential or
importance of L’ORÉAL as a customer to the company proprietary information of both companies is protected.
concerned. The only way to find out if it is acceptable
is to disclose it to your management and discuss the
matter openly.

16
 The way we work

5.6 - A member of my team has been dating his FOR MORE INFORMATION:
subordinate for a couple of months. They were pretty please read the policy on the “Employment of Family
discreet about it at work but people eventually found and Friends”.
out. I’m not supposed to know about it officially. It
has started off all sorts of rumours. Of course, I am
keeping an eye on things to make sure there can be no
evidence of favouritism - but what if they split up and
it all gets nasty? Should I do something about it - and Who to contact: If you have a concern about
if so, what? conflicts of interests, don’t keep it to yourself.
Speak to your manager, your Human Resources
This is a very sensitive situation. At L’ORÉAL, we Manager or your Ethics Correspondent; they
respect employees’ private lives, and therefore we will be able to help and support you (see also the
do not need or want to know about their romantic chapter on “I Have a Concern: Open Talk”).
relationships. However, we do have a legitimate interest
in their professional relationship, namely when one
reports to the other or is in a position of authority
or control over the other person. The situation you
describe is not appropriate because there is a conflict
of interests. A manager cannot be expected to judge
his/her subordinate objectively if he/she is romantically
involved. You should consult your manager or your
Human Resources Manager in order to discuss how
to handle this. Ideally, one of the employees should
change jobs, and we would endeavour to make sure
that this could be achieved tactfully. Depending on the
facts and circumstances, there may also be a sexual
harassment issue.

5.7 - Can a L’ORÉAL employee also have a personal

beauty blog?

It appears difficult for a L’ORÉAL employee to

participate in this type of blog since he or she can
neither criticise our products for loyalty reasons, nor
criticise the products of our competitors, since that
would not be fairplay. These blogs are only of interest
if they show true consumer opinion. We must not leave
ourselves open to criticism or be accused of influencing
the debate or lacking transparency.

17
As a business

GIFTS
& ENTERTAINMENT
Exchanging gifts and entertainment can help build understanding and improve working relationships, but
they can also cause a conflict of interests between personal interest and professional duty. When receiving
or giving gifts or entertainment, the “golden rules” are full disclosure to your management, staying within
reasonable limits and always asking oneself how this would be perceived by the wider public.

We must 6.4 - As part of my job, I organise numerous business

meetings, trips and conventions. Now a hotel where
+E
 nsure that all gifts and entertainment offered I often book rooms for L’ORÉAL employees has
are appropriate and in line with L’ORÉAL’s Ethical offered me a free weekend for my parents’ wedding
Principles anniversary. It’s a sweet gesture. Can I accept it?

+M
 ake sure that when establishing a new business No. Even if you are not personally going to benefit
relationship, all parties are aware from the outset of from the gift, accepting the offer makes it difficult
L’ORÉAL’s guidelines on gifts and entertainment. In to remain impartial when you arrange future hotel
turn, find out what our business partner’s policy is accommodation for L’ORÉAL. Even the appearance of
on these issues. That can go a long way to avoiding such a conflict of interests is inappropriate and should
any misunderstandings be avoided by politely declining the offer, and making
clear why you’re doing so.
+ Immediately disclose to our management any gift or
invitation that we have received, and, if necessary,
respect the internal disclosure procedures 6.5 - A supplier has just offered me a large hamper of
his products. I know it won’t have cost him much. So
can – and should – I accept it?
We must not
You should thank the supplier for his generosity, but
-A
 ccept gifts or entertainment unless they are clearly politely decline the gift. You can only accept gifts and
symbolic in value invitations which are symbolic in value. For example,
products with the supplier’s company logo or a box of
- Accept or give cash gifts chocolates is usually fine. If you think it would harm the
relationship were you to refuse, seek advice from your
Ethical? management to find an appropriate way of dealing with
the gift.
6.1 - May I offer a L’ORÉAL customer tickets to a
concert that I cannot attend?
6.6 - I am negotiating an increase in our shelf space
Someone from L’ORÉAL must be present and be able to with a customer. My contact is refusing to examine
conduct business with the customer as part of any such our proposal, arguing that our competitors are
outing. The same rule applies when accepting entertainment “nicer” to him. I have the impression he wants me to
from a supplier. It is only permissible if the entertainment give him a gift but he has not asked me for anything
is reasonable, usual and customary for your business specific.
relationship, and the provider is in attendance.
Let your management know about your doubts. It
might be necessary to talk with your customer’s
6.2 - We have just closed an important deal with a new management because it is unlikely that they encourage
customer. My Sales Manager has suggested that we take this type of behaviour from their employees. In
him to a club to celebrate the event. I thought that was any event, do not give way to temptation. Healthy
a good idea – until I discovered it was a lap-dancing negotiation with our customers is based on the quality
club! I feel really uncomfortable about offering this type of our products and on our price policy, and not on our
of entertainment. Am I being over-sensitive? capacity to give gifts to their employees.

Entertainment offered to customers should not only be FOR MORE INFORMATION:

reasonable but also acceptable. This type of club is not please read “The Way We Buy” and “The Way We Prevent
only likely to clash with the L’ORÉAL SPIRIT, but could Corruption”, as well as your local gifts and entertainment
also make the customer very uncomfortable, not to policy.
mention any member of your sales team who finds this
sort of “entertainment” distasteful. You should encourage
your Sales Manager to find a more appropriate option. In
the long term, that will reflect well on the Company.
Who to contact: If you have a concern about gifts
and entertainment, don’t keep it to yourself. Speak
6.3 - In order to sell off obsolete products, a supplier to your manager, your Human Resources Manager
just offered me a 15% personal discount. Can I accept it? or your Ethics Correspondent; they will be able
to help and support you (see also the chapter on
Except in the exceptional case of discounts agreed “I Have a Concern: Open Talk”).
with suppliers by L’ORÉAL, you must inform your
management of any discount offered by a supplier.

18
 The way we work

BRIBERY
& FACILITATION PAYMENTS
We believe that corruption is unacceptable and not in line with the L’ORÉAL SPIRIT. It is harmful for the
communities in which we operate, and is damaging for the Company. Corruption is prohibited in all the
countries in which we operate, particularly where representatives of public authorities are involved. We have
a zero tolerance policy when it comes to corruption, which includes “facilitation payments”. These are defined
as payments used to secure or speed up routine legal government actions, such as issuing permits or releasing
goods held in customs.

We must Ethical?
+E
 nsure that our business partners and 7.1 - I’ve been told I should hire a local “consultant”
intermediaries are informed of our standards and to help get all the necessary permits which we need
are committed to respecting them specifically when from a foreign government. This consultant requested
they are representing us in a country where the risk a large retainer and said that he would use the money
of corruption is high to “help move the process along”. Since we don’t
really know where the money is going, do we have to
+ Immediately inform our manager and our Country worry about it?
Manager or, for Corporate or Zone staff, the
member of the Group’s Executive Committee to Yes. If you suspect that any agent is acting improperly,
whom we report, if we become aware of any action you must not pay any such retainer or any other sum
that might be contrary to our corruption prevention until you have determined that no improper payments
policy have been or are being made.

+ Immediately inform our Country Manager or, for

Corporate or Zone staff, the member of the Group’s 7.2 - I am setting up a new office and the local
Executive Committee to whom we report, if facing authorities requested a small gratuity before they will
extortion or attempted extorsion, i.e., payment install our phone lines. May I make this payment?
of cash or of anything of value in order to avoid
the immediate harm to a L’ORÉAL employee or No. If the payment is not a legitimate installation fee,
representative and thoroughly document this you must not pay it.
demand

7.3 - I am in the process of supplying our products to

We must not a new client. A consultant who works for this client
contacted me and told me he could help me by
-O
 ffer, promise or give money, including a facilitation providing me with confidential information about this
payment or anything of value (gifts, entertainment, client.
etc.) to a representative of the public authority,
political party or politician, trade union or person You must refuse this offer and inform your manager. It
involved in trade unions will also probably be necessary to tell your client that a
third-party is trying to sell you confidential information
-O
 ffer, promise or give money or anything of value belonging to them.
(gifts, entertainment, etc.) to a charitable or
similar organisation with the aim of obtaining any FOR MORE INFORMATION:
advantage for L’ORÉAL from a representative of the please read “The Way We Prevent Corruption”.
public authorities or political party or trade union

-O
 ffer, promise or give money or anything of value
(gifts, entertainment, etc.) to an employee or
representative of another company that might Who to contact: If you have a concern about
lead them to breach their duty of loyalty to their bribery and facilitation payments, don’t keep it to
company yourself. Speak to your manager, your Internal
Control Manager, your Finance Director, your
-A
 ccept or solicit money or anything of value (gifts, Legal Director, your Purchasing Manager, your
entertainment, etc.) that might lead us to breach Human Resources Manager or your Ethics
our duty of loyalty to L’ORÉAL or be perceived as Correspondent; they will be able to help and
influencing a business relationship support you (see also the chapters on “Gifts and
Entertainment” and “I Have a Concern: Open Talk”).
-U
 se third parties to do something that we are not
allowed to or have not allowed ourselves to do
directly. This means that we need to exercise great
care in selecting and monitoring our consultants,
sub-contractors, agents and business partners

19
As a business

CONFIDENTIAL
INFORMATION
Information is valuable. The unauthorised disclosure of internal information can lead to a loss in value and
be detrimental to L’ORÉAL. We must all ensure the protection of internal information, strictly following the
Group’s rules on this subject. Those of us who have access to confidential information belonging to business
partners are under a similar obligation to protect it from disclosure.

We must 8.3 - The other day, I was taking a potential customer

to a meeting. On the way to the meeting room, we
+L
 imit disclosure of internal information to people walked past a colleague’s office. His door was open,
with a legitimate “need to know” that serves and he was talking to another customer about our
L’ORÉAL’s interests pricing conditions on his speakerphone. Just as we
passed, we could hear him offering some special
+K
 eep up to date of the Group’s rules on information deals - all within my customer’s hearing! Surely he
management should be more careful?

+E
 nsure the safe keeping of all confidential We all need to take the necessary measures to protect
employee, consumer, customer and supplier the confidentiality of information, even within the
records, both paper and electronic workplace: for example, by following a “clean desk”
policy, locking files away, changing passwords regularly,
+B
 efore sharing internal information with third and exercising caution when using speakerphones.
parties outside L’ORÉAL (including namely You can never know who may be passing, and even
members of our family or when using social media), amongst L’ORÉAL employees, commercially sensitive
check what we have the right to communicate information should only be shared on a “need-to-know”
basis.

We must not
8.4 - A colleague of mine who has left L’ORÉAL told
-D
 iscuss or work with internal information in a public me he has just realised he still had internal L’ORÉAL
area where conversations can be overheard or data documents at home. What advice can I give him?
compromised
If these documents are copies, you should ask him
- Disclose a previous employer’s internal information to destroy them. If they are originals, they must be
forwarded to a L’ORÉAL employee who is authorized to
-K
 eep any internal information (including all copies receive such information. Talk to your manager to make
of original material) upon leaving L’ORÉAL sure that the right actions are taken.

FOR MORE INFORMATION:

Ethical? please read “The Way We Buy” regarding our relationship
with suppliers, and “The Way We Compete” on our
8.1 - My friends often ask me about my work at relationship with competitors and clients.
L’ORÉAL: they’re curious as to just what it is we put
in our products, and what new launches we’ve got
up our sleeve. Obviously, I know quite a lot of the
answers through my work - so how much can I tell
them? Who to contact: If you have a concern about
confidentiality, don’t keep it to yourself. Speak to
Any information (written, electronic, verbal or any other your manager, your Human Resources Manager
form), which is not publicly available and to which or your Ethics Correspondent; they will be able
you have had access as a L’ORÉAL employee, should to help and support you (see also the chapter on
be considered internal. Revealing such information, “I Have a Concern: Open Talk”).
even to trusted friends, is not appropriate. It may harm
L’ORÉAL’s interests.

8.2 - Today we are living in a world where

communication is easier and limitless in this digital
revolution. This challenges the confidentiality
principles in our Code of Ethics.

It is true that, in the digital world, ensuring

confidentiality is becoming increasingly difficult, but
as such is all the more important. It is up to everyone
to acquaint themselves with the Group’s rules on the
subject, namely on the proper use of social media and
of information and communication technologies.

20
 The way we work

REPRESENTING
THE COMPANY
L’ORÉAL’s reputation depends on the behaviour of each and every one of us.

We must 9.2 - Our team took part in a conference which

involved staying overnight and having dinner at the
+ Act with L’ORÉAL’s best interests at heart conference hotel. One of my team members drank
more than he should have during the dinner and
+ Demonstrate L’ORÉAL’s Ethical Principles in our started behaving badly, telling stupid jokes and being
professional behaviour and language aggressive with the hotel staff. What should I say to
him about his behaviour?
+ Ensure there is no confusion between our opinions or
personal interests and those of the Company Although the incident took place during the evening,
your team member was still on Company business. For
+ Avoid giving our opinion on colleagues and the others around him, he was representing L’ORÉAL. It is
workplace on professional development sites (i.e., clear that his behaviour was not acceptable.
LinkedIn)

+ Always identify ourselves as L’ORÉAL employees when 9.3 - I attended an international conference, and
we use social media as part of our professional activities during the welcome cocktail, I was speaking with
another participant about my activities at L’ORÉAL.
+ Always keep in mind that nothing is “secret” or “private” Later that evening, I realised that the young woman
on the Internet who had been beside us was a journalist covering the
conference. Even though I did not reveal anything
+ Always ensure that any digital communication on highly confidential, I would not want my statements
L’ORÉAL or one of its brands has undergone adequate to appear on the front page.
preparation
When you are in public, you must always keep in
mind that when you are in a professional or personal
We must not situation with a journalist present, what you say may be
repeated. Contact your Communications Director who
- Speak or write or take any commitment on behalf of will know how to advise you.
L’ORÉAL unless duly authorised

- Speak or write on subjects falling outside our personal 9.4 - Sometimes the Internet seems to be full
expertise of misinformation about L’ORÉAL. Isn’t it my
responsibility to correct it?
- Use L’ORÉAL’s letterhead or e-mails to express personal
views or for personal business No. If there’s erroneous information circulating in
public, you should let your Public Relations Department
know about it and they will take action if required. But
Ethical? without authorisation no employee may post Company
information or a Company position on the Internet or
9.1 - I visited a colleague’s blog and saw he’d elsewhere.
expressed some personal views on L’ORÉAL’s
management. He had not said that he was a L’ORÉAL
employee, but it was pretty easy to guess from other 9.5 - For the first time, I am attending a trade
information he had given such as “I work for the no. 1 association meeting. What steps should I take to
cosmetics company”! Should I have a word with him make sure there is no risk for L’ORÉAL?
about this?
Check with your Legal Director what type of
Blogs are becoming a popular mode of expression. information can be freely discussed and take the online
When participating in blogs, employees must make it training in competition law. You should also read
clear that they are expressing their own personal views, “The Way We Compete” and “The Way We Prevent
and take all necessary precautions to ensure that these Corruption”.
are not in any way mistaken for those of L’ORÉAL. You
should raise this issue with your colleague first, as he
may not have realised how his actions could be against
L’ORÉAL’s interests. If necessary, you may decide to
discuss it with your manager. Who to contact: If you have a concern about
representing the Company, don’t keep it to
yourself. Speak to your manager, your Public
Relations Manager, your Human Resources
Manager or your Ethics Correspondent;
they will be able to help and support you (see also
the chapter on “I Have a Concern: Open Talk”).

21
As a business

PRIVACY
& DATA PROTECTION
We all have a right to privacy.
L’ORÉAL is committed to respecting the confidentiality of personal information of all its stakeholders,
including its employees, consumers and business partners. Only such data as is necessary for the effective
operation of L’ORÉAL is acquired and retained by the Company.

We must Ethical?
+M
 ake sure the persons from whom we collect 10.1 - Why does L’ORÉAL need to have access to
personal data are informed of the type of personal data?
information we are collecting, how we plan to use
it and how they can contact us if they have any L’ORÉAL needs to collect and use personal data
questions in order to meet the various requirements of its
employees, consumers and stakeholders. For example,
+ Collect only the personal data that is necessary we use e-mail addresses to send consumers or
shareholders or candidates the information they need.
+D
 estroy or correct any inaccurate or incomplete We also collect personal data in marketing situations
data such as running prize draws and for CRM databases.
We need personal data about our employees to be
+ Make sure such data is securely stored able to manage their pay and career or for legal or
safety reasons. We must collect personal data when we
+W
 ithin L’ORÉAL, ensure we only provide such data decide to work with a new customer or supplier. Lastly,
to authorised persons, on a strict “need-to-know” we collect personal data during consumer studies or in
basis our evaluation centres.

+S
 eek legal advice before transferring such personal
data outside the country where it was collected 10.2 - During a professional trip, my suitcase
containing a USB key with customers’ personal data
+ Respect the right to privacy of our colleagues was stolen. Unfortunately, it was not encrypted, but I
don’t see what the “thief” could do with it.
+E
 nsure that the third parties to whom we could
delegate the collection or use of personal data The loss of personal data may result in legal action, can
comply with these principle damage L’ORÉAL’s reputation and may adversely affect
people whose data have been lost. Identity theft based
on personal data lost in this way is becoming more
We must not and more common. Therefore, it is crucial to respect
the internal rules and procedures on data encryption.
-C
 ollect “sensitive” information (related especially Wherever it is possible, make the personal data
to state of health, ethnic origin, sexual orientation, anonymous or use code names.
political opinions, religion) without the consent of
the person concerned or only if the law requires it
10.3 - For our evaluation studies, we have access to
-P
 rovide personal data to anyone outside L’ORÉAL, personal data on our volunteers. Certain information
unless legally required to do so or when using could interest other companies who are ready to buy
technical service providers or with the person’s it. Do we have the right to sell it?
authorisation
At L’ORÉAL, we are committed to protecting the
-H
 old this information longer than is necessary to personal information that we can collect as part of our
meet the legal or business reason for which it was activities. It is not possible to use such personal data
acquired without previously informing the people concerned or
without their written agreement.
-A
 ccess or store personal data, unless we have the
appropriate authorisation and a clear business need
for that information 10.4 - I must transfer personal information on
consumers to an agency in another country. Whom
should I ask for advice?

The best thing would be to contact your Legal Director.

Laws vary greatly from country to country. Moreover,
we should not transfer personal information to a third-
party without ensuring they have signed a commitment
to respect our standards for protecting personal data.

22
 The way we work

10.5 - Our Consumer Department just received an

e-mail from a consumer who wants to know what
personal information we have on her and asking us to
Who to contact: If you have a concern about
destroy it. Am I obliged to do so? privacy and/or personal data, don’t keep it to
yourself. Speak to your manager, your Legal
Yes, we always respect the request of a consumer who Director, your Human Resources Manager or your
does not want us using personal data for marketing Ethics Correspondent; they will be able to help
purposes, and we must ensure that the listings are and support you (see also the chapter on “I Have a
regularly updated. In certain countries, there are lists on Concern: Open Talk”).
which consumers can register if they do not want their
personal information used. Ask your Legal Director for
help in how to best answer this consumer’s request.

10.6 - I would like to send one of my colleagues a

surprise birthday gift to her home. I asked Human
Resources to give me her personal address but
they say they can’t tell me, because that would be
“infringing her right to privacy”! Isn’t this going a bit
over the top?

The Human Resources Department’s response is totally

appropriate – all employee personal data has to remain
strictly confidential. They can’t start making exceptions.

10.7 - I recently overheard my manager talking with

Human Resources about one of my colleagues and
the fact that she is seriously ill. In my spare time, I
volunteer for a charity that helps people with serious
illness and I would like to know if there is anything I
can do to help. Can I approach my colleague directly
or speak to my manager first?

No, do not contact your colleague directly but your

manager or the Human Resources Department instead.
If they think it is appropriate, they will contact your
colleague to let her know. In order to respect your
colleague’s privacy, you should not, of course, share the
information you have with anyone.

23
As a business

USE OF
COMPANY RESOURCES
Company resources are intended to help employees achieve L’ORÉAL’s business goals. Misused or wasted
Company resources, including employee time, hurt us all and adversely affect the operational and financial
performance of L’ORÉAL.

We must 11.3 - I keep receiving “joke of the day” e-mails from a

friend in another department, some of which are very
+R
 espect and protect Company assets to ensure funny. I’d like to send them on to my colleagues and
that they are not lost, damaged, misused or wasted, give them a smile on a Monday morning, but I’m not
nor loaned to others, transferred, sold or donated sure if my manager will approve. What should I do?
without authorisation Leave her off the list?

+R
 ecognise that all Company assets and documents You shouldn’t forward these “jokes”. Remember
belong to L’ORÉAL that not everyone has the same sense of humour. In
particular, you should bear in mind that the Company’s
e-mail and internet access systems must never be used
We must not to access, store, send or publish any material which
is inconsistent with the L’ORÉAL SPIRIT – especially
-U
 se Company assets for personal purposes. when it comes to respect for individuals. This includes,
Limited use of communication tools such as e-mail, of course, pornographic or sexually explicit images,
telephone and the Internet may be acceptable so political or religious content, racist comments or
long as this does not incur any unreasonable costs anything that promotes violence, hatred or intolerance.
and does not interfere with our job responsibilities

- Inappropriately use computer systems, corporate 11.4 - Can I sell the products that we purchase in our
e-mail accounts and the Internet Company store to friends with no mark-up? Or can
I sell them to my friends at market prices?
-U
 se assets belonging to a third party (photos, films,
articles, etc.) without ensuring that L’ORÉAL has the The products that you can purchase at the Company
right to use them store are strictly reserved for your and your family’s
personal use, and must not be resold at any price.
-A
 llow access to our contacts list/professional
electronic address book via social media sites
(Facebook, LinkedIn, etc.)

Who to contact: If you have a concern about the

Ethical? use of company resources, don’t keep it to yourself.
Speak to your manager, your Human Resources
11.1 - I suspect that one of my team members has Manager or your Ethics Correspondent; they
been running an outside consulting business during will be able to help and support you (see also the
Company time, using his Company laptop and email chapter on “I Have a Concern: Open Talk”).
to do so. I mentioned it to a friend in Information
Services. He can access the guy’s e-mail, and has
offered to help me do a bit of sleuthing to find out
what’s going on. Is this OK?

No. If you have suspicions of this kind, you should raise

them directly with your manager. There are specific
procedures for accessing employee e-mail accounts
in connection with a misconduct investigation. Even
though your friend in IT has access to these accounts,
he should not use it for this purpose without proper
authorisation through official Company channels.

11.2 - Our printer at home is broken, and my wife

needs to send her CV out for a possible job as a
matter of urgency. Is it OK if I type it up and print it at
work?

You may use the computer to type personal

documents, so long as this is occasional, reasonable,
does not interfere with your job responsibilities and
is done during non-working hours.

24
 The way we work

FINANCIAL & BUSINESS RECORDS

& THE FIGHT AGAINST
MONEY LAUNDERING
We all have a duty to make sure that all our records, financial or otherwise, are accurate. Accuracy is paramount
for a successful business. This is an essential part of running our business legally, honestly and efficiently. In
particular, it is crucial to being able to provide transparent, regular and reliable information to our shareholders.
Lastly, we must ensure that our activities are not used to launder money from criminal activities.

We must 12.2 - Life gets very hectic sometimes, and I can’t

always find all the receipts I need to claim my
+P
 lay our part in ensuring that accurate financial expenses. Is it all right if I add a few fictitious
and business records, including financial and non- expense items that are less than the amount requiring
financial reporting, are maintained at all times a receipt, just to make it up to the right total? It
wouldn’t be dishonest in any way, as I wouldn’t be
+M
 aintain records securely and follow any guidelines coming out ahead. I’d only be making sure I received
on record retention my due.

+F
 ollow internal due diligence procedures so that we No. This is not OK. It means the expense reports
can ensure that we are working with clients with are inaccurate, and that translates into inaccurate
legitimate activities and whose money does not accounting records. You need to take responsibility for
come from criminal activities looking after all receipts; that’s the only guarantee that
you’ll receive the settlement you’re due.
+ Cooperate with our internal and external auditors

12.3 - One of our customers has asked if they can

We must not pay through a mix of different accounts, using
a combination of cash and cheques. Is this OK?
-S
 ell, transfer or dispose of any L’ORÉAL assets What should I do?
without proper authorisation and documentation
You should be especially careful with these sorts of
-A
 ccept cash transactions. If there is no other transactions. It could be money-laundering, a process
possibility, and only subject to the authorised in which funds obtained through illegal means (e.g.,
legal amount, cash transactions must be expressly drugs, bribery, prostitution, etc.) are concealed or made
authorised, properly recorded and documented to look legitimate. You must take all possible steps
to ensure that this is a bona fide transaction. These
- Conceal payments via the use of third parties payments can only be accepted under exceptional
circumstances and after having received approval from
your manager. Among the red flags to look out for
Ethical? are: payments made from currencies other than that
specified in the invoice; attempts to make payments in
12.1 - I’ve been asked to check the sales report cash; payments made by someone who is not a party
prepared by my manager for the year end. In doing to the contract; payments to and from an account other
so, I’ve spotted what I think is an error, which than the one used in the normal business relationship;
nobody else seems to have picked up on. I’m rather and requests to make an overpayment. If the account
nervous about mentioning it, because I don’t want is not in the name of the contracting company, the
to jeopardise my relationship with my manager. payment must be refused.
What should I do?
FOR MORE INFORMATION:
The reason you were asked to check the sales report is on accuracy in financial and business records
precisely to make sure there were no mistakes. If you do and on the fight against corruption, please read
not disclose this, you are not doing your job properly “The Way We Prevent Corruption”.
and you are not serving the interests of the Company.
You should talk to your manager about what you have
found. He or she has no reason to be angry with you;
on the contrary, you’ve done well to avoid inaccurate
information being passed up the line. Who to contact: If you have a concern about the
accuracy in financial and business records, don’t
keep it to yourself. Speak to your manager, your
Finance Director, your Human Resources Manager
or your Ethics Correspondent; they will be able
to help and support you (see also the chapter on
“I Have a Concern: Open Talk”).

25
As a business

INSIDER
TRADING
While L’ORÉAL does not wish to restrict the freedom of employees to make appropriate personal investments,
each of us must always bear in mind the rules with regards “insider trading”.

We must
+B
 e aware that using inside information to make
Who to contact: If you have a concern about
investments could fall within the scope of insider insider trading, don’t keep it to yourself. Speak
trading laws to your manager, your Legal Director, the
Internal Advisor on Stock Market Ethics or your
+M
 aintain the confidentiality of any inside Ethics Correspondent; they will be able to help
information to which we may have access in order and support you (see also the chapter on “I Have
to avoid any accidental disclosure a Concern: Open Talk”). Be careful however not to
reveal any inside information of which you have
knowledge, if applicable.
We must not
-B
 uy or sell shares in L’ORÉAL or any other company
if we have inside information at that time

-D
 isclose inside information to anyone outside the
Company

-D
 isclose inside information to anyone within the
Company

Ethical?
13.1 - I’m not a legal expert. What exactly is “inside
information”?

“Inside information” is a concept defined by law.

In broad terms, it relates to non-publicly available
information which a reasonable investor could use as
one of the reasons for making an investment decision.
Such information can relate to the L’ORÉAL Group,
to its activities, its customers or suppliers, or another
company with which the L’ORÉAL Group is in contact.
You will find additional information in L’ORÉAL’s Stock
Market Ethics charter.

13.2 - I’ve just heard that L’ORÉAL is about to acquire

another company. This sounds like an excellent time
to buy stock in one or the other – or both, since the
values are bound to rise when the deal is announced.
Is it OK for me to go ahead and do so?

No, you cannot. As a L’ORÉAL employee, you are most

likely to be considered an “insider” and therefore cannot
buy or sell stock in either L’ORÉAL or the other company
until the deal has been announced to the public.

13.3 - I realise that I can’t buy L’ORÉAL stock based

on inside information myself. But what if I just
“happened to mention” to my girlfriend that now
might possibly be a good time to buy. Would that be
OK?

No. It would be as unacceptable as if you were buying

it yourself. As well, even if your girlfriend did not follow
your advice, the simple fact of passing on a rumour is a
violation of our ethics and the law.

26
 The way we work

TAX
L’ORÉAL aims to be a good corporate citizen wherever it operates. This namely means scrupulously respecting
tax laws and paying in full all local and national taxes as required by those laws.

We must
+K
 eep accurate and comprehensive books and Who to contact: If you have a concern about tax,
records don’t keep it to yourself. Speak to your manager,
your Finance Director, your Human Resources
+ Prepare our tax forms Manager, your Ethics Correspondent or the
Group’s Tax Department; they will be able to
help and support you (see also the chapter on
We must not “I Have a Concern: Open Talk”).

-K
 nowingly allow L’ORÉAL to evade its tax
obligations

Ethical?
14.1 - I have been approached by a supplier who says
he has a cast-iron way to save us money. He’s offering
to reroute the paperwork for purchasing the end of
year order of their goods via a third country to avoid
paying sales tax (VAT) that they would otherwise
charge us. It sounds like a clever scheme – can I give
it the go-ahead?

No. Any attempt to evade meeting our tax obligations

in full – which is in effect what this would be – is illegal
and unethical. L’ORÉAL’s budgeting includes provisions
to pay all legitimate taxes.

14.2 - I believe that we made a mistake on a tax form

a few years back that reduced our taxation rate at the
time. What should I do?

As a principle, we pay taxes in accordance with

local law and are considered trustworthy by the tax
authorities. You must talk about it with your Finance
Director or a member of the Group’s Tax Department
so that they can check if it is truly an error, and, if so,
how to approach the tax authorities as well as deciding
which steps to take to ensure that this error is not
reproduced in the future.

14.3 - There are quite a few articles in the media

on companies evading taxes. Could this happen to
L’ORÉAL?

At L’ORÉAL, we pay all taxes required in all

the countries in which we operate. We see this as one
of the ways we can make a positive contribution to
the countries and communities in which we are present.

27
RESPECTING OUR COMMITMENTS AS AN EMPLOYER

“We aim to make L’ORÉAL a great place

in which to work. We know that
our employees are our greatest assets.”
Table of contents
PAG E 2 9
Health, safety and security

PAG E 3 0
Diversity

PAG E 3 2
Harassment and bullying

PAG E 3 3
Sexual harassment

28
 The way we work

HEALTH,
SAFETY & SECURITY
All of us who work with and for L’ORÉAL have a right to a healthy, safe and secure working environment and
safety at work depends on all of us.

We must Yes, you should consult your Human Resources

Manager in order to discuss possible solutions to avoid
+T
 ake every reasonable precaution to maintain a safe this kind of situation.
and healthy working environment

+E
 nsure we are not putting ourselves or others at 15.4 - I have a colleague who seems to be terribly
risk by our actions stressed right now. I tried to talk to him about it, but
he refused to do so. Yesterday, he fainted at work.
+E
 nsure that we know what to do if an emergency What should I do?
occurs at our workplace
It is important that Human Resources and your
+ Report
 immediately to our site’s safety manager or colleague’s manager be immediately informed so that
our management all accidents, however minor as they can act quickly. If you are not sure whether this
well as any behaviour, installations or items likely to has been done, do not hesitate to escalate the matter
compromise the safety of our working environment on your side.

We must not 15.5 - I have just learnt that one of our sub-
contractors has been drinking on our premises. Since
- Ignore the Company’s rules on health and safety at he is not technically a L’ORÉAL employee, is it my
work concern?

You should report to your manager any behaviour

Ethical? which could compromise the safety of your working
environment or put anyone at risk.
15.1 - My manager says she’s worried I’m not getting
enough sleep, and has suggested I shouldn’t go out
so much in the evenings after work. She says she’s
concerned I might doze off and have an accident. OK,
so once or twice I’ve been a bit sleepy – but I can still Who to contact: If you have a concern about
do my job. Surely it’s none of her business what I do health, safety and security, don’t keep it to yourself.
out of hours? Don’t I have the right to a private life? I Speak to your manager, your Health and Safety
think she’s being petty. What should I do? Manager, your Human Resources Manager or your
Ethics Correspondent; they will be able to help
How you spend your evenings is up to you. But if your and support you (see also the chapter on “I Have a
tiredness is putting yourself or others at risk, then your Concern: Open Talk”).
manager is right to raise the matter with you - although
she should do so with sensitivity and respect for your
privacy. Although we respect employees’ private lives,
behaviour which might create a safety hazard for you or
your colleagues cannot be accepted. There can be no
compromise on safety.

15.2 - My production supervisor has instructed me to

exceptionally disable a safety device that slows down
the production line. What should I do?

You should never bypass, disconnect or disable any

safety device or monitoring equipment without the
proper prior approval of a safety representative. If your
production supervisor insists, you must refuse and
inform the site management and your HR. Safety is an
absolute commitment that should not be compromised
by production schedules or for any other reason.

15.3 - As a sales representative, I often drive after dark

in large cities and rural areas. Sometimes, I don’t feel
safe. I have raised the security issue with my manager
but he has not acted on my concerns. Should I take
this up with someone else in the Company?

29
As an employer

DIVERSITY
The diversity of individual talents in our workforce strengthens our creativity, and allows us to develop and
market relevant products. L’ORÉAL values all types of beauty.
L’ORÉAL is an inclusive, equal opportunity employer. We facilitate the professional integration of people who
are under-represented in the workforce, in particular people with disabilities and under-represented social
and/or ethnic groups.

We must 16.2 - HR suggested I integrate a disabled person

into my team. I know that diversity is important to
+S
 upport and promote L’ORÉAL’s commitment to L’ORÉAL, but I am afraid that this person will often be
diversity, namely with regards Human Resources, on sick leave to the point where it could disrupt the
Marketing, Purchasing and Contribution to rest of the team, and I would be obliged to give him
Communities special treatment, which will create jealousy on the
part of other team members.
+ Ensure
 that our suppliers, customers and business
partners are aware of L’ORÉAL’s diversity policy These are preconceived notions. Experience shows that
the presence of disabled persons does not materially
change work relations. For disabled candidates as
We must not with anyone, recruiting is based on skills. The only
difference is that the compatibility of the job position
-D
 iscriminate or harass/bully on the basis of: is systematically checked. Some adaptation measures
- gender may be necessary but it is in fact rarely the case.
- disability
- marital status or family situation
- sexual orientation 16.3 - A member of my team just turned 50. I wanted
- age to organise a small party to celebrate, but she did
- political and philosophical opinions not want to, saying that L’ORÉAL does not offer any
- religious beliefs professional future for seniors and that she does not
- union activity want to draw attention to her age. What should I say
- ethnic, social, cultural or national origin to her?
This prohibition against discrimination applies not
only to recruitment, but also to all decisions relating Reassure your colleague and ask her to meet with her
to training, promotion, continued employment Human Resources Manager to talk about her career
and working conditions in general, as well as our plan. L’ORÉAL is committed to offering everyone a
relationships with our suppliers, clients, business dynamic career, regardless of age, and allows everyone
partners and third parties to contribute to the development of their career.

Ethical? 16.4 - One of my colleagues did not select a

supplier who, in my opinion, seemed to meet all
16.1 - What exactly does L’ORÉAL mean by our expectations. Given comments made by this
“discrimination”? Is it the same as the definition colleague, I suspect that it is due to the supplier’s
given by the law in my country, or is it different? nationality and ethnic origins. What should I do?

The first rule is that L’ORÉAL respects national laws Any discrimination based on skin colour, nationality
and therefore any employee violating the discrimination or ethnic origin is unacceptable to L’ORÉAL. It denies
laws in their country may be sanctioned. But there may the respect that each of us deserves. Try to talk about
be countries where the law on discrimination does it with your Diversity Correspondent, and otherwise,
not prohibit certain behaviours which the Company you should raise the matter with your manager or
finds unacceptable. For example, L’ORÉAL is opposed Purchasing Manager.
not only to direct discrimination, but also to indirect
discrimination. Direct discrimination means any
action taken with regard to jobs, training, promotions, 16.5 - I do not feel comfortable when I hear jokes
continued employment or any other aspect of working in poor taste about some of my colleagues who
life which means those affected do not enjoy equal are homosexual. What should I do? Should I speak
treatment or opportunities. Indirect discrimination with HR?
is any action which, while apparently neutral, puts
anyone with a particular gender, age, disability or other Homophobia is completely unacceptable. Each of
characteristic at a disadvantage compared to others. us has the right to be respected by others. We want
an open and inclusive working environment. If you
encounter this type of problem, try to make those
making the jokes understand that their behaviour is not
acceptable. If not, talk to your manager, your Human
Resources Manager, your Diversity Correspondent or
your Ethics Correspondent.

30
 The way we work

16.6 - I like to wrap up the working week with a Friday

evening team meeting so that we can discuss any
issues that came up during the week. I know that this
Who to contact: If you have a concern about
creates difficulties for two members of my team who, diversity, don’t keep it to yourself. Speak to your
for religious reasons, prefer to leave early on Fridays. manager, your Human Resources Manager,
Is this indirect discrimination? your Diversity Correspondent or your Ethics
Correspondent; they will be able to help and
It could be indirect discrimination if you do not have a support you (see also the chapter on “I Have a
legitimate need to hold the meeting on Friday evenings, Concern: Open Talk”).
or if there are more appropriate ways to meet your needs.
You appear to have a legitimate need for the meeting
(monitoring your team’s progress and being available
for their questions) - but do you really have to hold it on
a Friday evening? Could you not obtain the same result
by holding the meeting earlier in the day – or first thing
Monday morning?

16.7 - I keep hearing that diversity is important for the

Group. Does that mean I should only hire or promote
women or people from ethnic minorities?

No, this is not what is expected. At L’ORÉAL, we hire on

the basis of merit, and therefore you should select the
best candidate for the job. But remember that diversity
is not just limited to women and ethnic minorities.
It includes other groups who are often discriminated
against, such as disabled people, older people, and so on.

16.8 - If I share the same religious convictions as some

of my colleagues, can I invite them to a prayer group?

You can invite employees sharing the same faith.

However, we ask that everyone respect the beliefs of
others. This means refraining from proselytizing (i.e.
attempting to convert others).

16.9 - I am about to go on maternity leave and am

concerned about what will happen when I come back
and my future career opportunities. Who should I ask
for advice?

L’ORÉAL’s policy is to support employees during their

maternity leave. In addition to paid maternity leave,
L’ORÉAL guarantees the reintegration of employees at
the end of their maternity leave, in their former position
or at an equivalent position in terms of status and
salary. You should discuss the matter with your Human
Resources Manager before you go on maternity leave.

31
As an employer

HARASSMENT
& BULLYING
Each of us has the right to respect and human dignity. At L’ORÉAL, that principle is fundamental to the way we
work. Any behaviour or action likely to infringe this right, and in particular any form of harassment or bullying,
is not acceptable.

We must
+S
 upport and promote L’ORÉAL’s commitment to Who to contact: If you have a concern about
a workplace free from all bullying and harassment harassment and bullying, don’t keep it to yourself.
Speak to your manager, your Human Resources
+ Be
 courteous: treat our fellow workers and business Manager or your Ethics Correspondent; they
partners the way we would like them to treat us will be able to help and support you (see also the
chapter on “I Have a Concern: Open Talk”).

We must not
-K
 nowingly hurt or harass or set a person up to make
a mistake

Ethical?
17.1 - What exactly does L’ORÉAL mean by
“harassment” and “bullying”? I don’t think we have a
law on this in my country.

The first rule is that L’ORÉAL respects local law and

therefore any employee violating the harassment laws
in their country may be sanctioned. But there may be
countries where L’ORÉAL considers that the law on
harassment does not prohibit certain behaviours which
the Company finds unacceptable. Depending on the
circumstances, certain behaviours may be considered
inappropriate, such as:
- Actions intended to cause hurt or upset
- Deliberately setting a person up to make a mistake
- Humiliation or intimidation
-P hysical or social isolation (the so-called “silent
treatment”)
Harassment can also exist between colleagues. There
may be no law on this particular subject in your
country. You will, however, probably find that these
types of behaviour are legally prohibited, even if it is
not referred to as harassment or bullying.

17.2 - My manager can be highly intimidating. I know

she’s pushing us hard to deliver quality work, but
at times she can really humiliate people, and it’s
affecting the morale of the whole team. Is there
anything I can do about it?

Your manager is expected to challenge and drive

her team to deliver the quality of work we expect
at L’ORÉAL. This may mean that she will criticise or
comment on team members’ performance. However, a
manager is also expected to treat team members with
respect and act with due sensitivity. If you feel that
you are not being treated in a professional manner,
you should try and speak to your manager. You can
also consult your Human Resources Manager. A good
working environment can only occur with the support
and involvement of us all - managers and staff alike.

32
 The way we work

SEXUAL
HARASSMENT
Each of us has the right to respect and human dignity. At L’ORÉAL, that principle is fundamental to the way
we work. Any behaviour or action likely to infringe this right, and in particular any form of sexual harassment,
is not acceptable.

We must 18.3 - I have a meeting with a client and he’s always

touching me and making comments about my figure
+ Support
 and promote L’ORÉAL’s commitment to and how he’d buy more from us if I went to dinner
a workplace free from all sexual harassment with him. It’s a client, not another L’ORÉAL employee
so I’m not sure L’ORÉAL will do anything about it.
+ Abstain
 from any sexual harassment both internally
and externally with regards third-parties with whom You should speak to your manager or your Human
we are in professional contact Resources Manager. L’ORÉAL’s policy is to ensure that
their employees are not subject to sexual harassment
including from business partners.
We must not
- Continue
 any behaviour which we have been told is
unwanted
Who to contact: If you have a concern about
sexual harassment, don’t keep it to yourself. Speak
Ethical? to your manager, your Human Resources Manager
or your Ethics Correspondent; they will be able to
18.1 - What exactly does L’ORÉAL mean by “sexual help and support you (see also the chapter on
harassment”? Is it the same as the definition given by “I Have a Concern: Open Talk”).
the law in my country, or is it different?

The first rule is that L’ORÉAL respects local law

and therefore any employee violating the sexual
harassment laws in their country may be sanctioned.
But there may be countries where L’ORÉAL considers
that the law on sexual harassment does not prohibit
certain behaviours which the Company finds
unacceptable. Depending on the circumstances, certain
behaviours may, because of their gravity or frequency,
be considered inappropriate such as:
- Unwelcome or inappropriate physical contact,
emails, jokes, looks and other gestures, comments,
invitations or requests of a sexual nature
- Distributions or displaying of documents, posters,
objects, etc. of a sexual nature
- Conditioning job advancement or any other benefit
of employment on sexual or romantic activity
Sexual harassment can affect both men and women. It
can occur at a L’ORÉAL work location or at any other
venue where we conduct business.

18.2 - During a team party, one of my colleagues

found that our manager was acting inappropriately
toward her in terms of body language and comments.
She’s afraid to speak out, though, as she doesn’t
want to come over as a prude, or jeopardise her
professional career. What should I do about it?

You should encourage your colleague to speak with the

manager directly if she feels comfortable about doing
so. If not, she can also raise the matter with the Human
Resources Manager. If your colleague does not take
action, then you should report what she has told you
to HR – even if you don’t have all the facts or haven’t
observed the harassment yourself. It is critical to stop
offensive behaviour before things get out of hand.

33
RESPECTING OUR COMMITMENTS
AS A RESPONSIBLE CORPORATE CITIZEN

“We play our part in creating

a world of beauty and fairness.”

Table of contents
PAG E 3 5
Political activities
and lobbying

PAG E 3 6
Environmental stewardship

PAG E 37
Contribution to
the community

34
 The way we work

POLITICAL ACTIVITIES
& LOBBYING
L’ORÉAL does not contribute to political parties, politicians or related institutions. However, L’ORÉAL, as a
leader in the cosmetics industry, believes it is its duty to be proactive and take part in the public decision-
making process in the countries in which it operates.
L’ORÉAL respects its employees’ right to participate as individuals in the political process – so long as they
make sure that, in doing so, they do not represent the Company.

We must 19.3 - I want to run for political office in my city. On

my posters, I intend to mention the fact that I work
+ If we participate in personal political activities, for L’ORÉAL.
clearly specify that we do not represent L’ORÉAL in
any way. This is not appropriate since it could be seen as
L’ORÉAL implicitly supporting your candidacy.
+ Inform our manager if our participation in political
activities could prevent us from fulfilling our duties
at L’ORÉAL or create confusion between our 19.4 - What exactly is lobbying? When we hear
personal political views and those of L’ORÉAL (see about it in the media, it does not always have a good
the chapter on “Conflicts of Interests”) reputation.

+S
 trictly respect L’ORÉAL’s rules regarding gifts Lobbying is an activity that involves contributing to the
and entertainment and bribery prevention (see the public decision-making process relating to regulations
chapter on “Bribery and Facilitation Payments”) likely to affect our activities so that the public decision-
maker can understand how these regulations could
affect us. If we think that such regulations could be
We must not detrimental, we make this known and try to limit
its effects. L’ORÉAL regularly communicates on its
-U
 se Company funds and resources (including positions and the public authorities and institutions
Company time, phones, paper, e-mail and other with which and via which it takes part in this debate,
Company assets) to carry out or support our with the strictest respect for all relevant applicable laws.
personal political activities

- Use the workplace as a political tribune 19.5 - Should employees voice their political opinions
and commitments in the workplace?
-L
 ead to believe that L’ORÉAL supports our personal
political activities L’ORÉAL respects its employees’ right to participate as
individuals in the political process, but the workplace is
-E
 nter into discussions with representatives of public not the right place to discuss politics.
authorities or political parties with regards local
or international regulations without the express
authorisation of our Country/Entity Manager and
subject to being registered on the lobbyists register
if one exists Who to contact: If you have a concern about
political activities or lobbying, don’t keep it to
yourself. Speak to your manager, your Human
Ethical? Resources Manager or your Ethics Correspondent;
they will be able to help and support you (see also
19.1 - I do some volunteer work for a local candidate the chapter on “I Have a Concern: Open Talk”).
whose policies are very much in line with L’ORÉAL’s
values. May I use the copy machine to run off a few
flyers?

No. Do not use Company time or resources of any kind

to support political activities.

19.2 - My manager has asked me if I’d like to make a

donation to his daughter’s mayoral campaign. Is this
appropriate?

No. Even if your manager isn’t pressuring you, any such

request, however innocent, is inappropriate and could
be coercive.

35
As a responsible corporate citizen

ENVIRONMENTAL
STEWARDSHIP
L’ORÉAL respects the environment, and seeks to minimise its environmental impact. We aim to communicate
openly about our achievements in this area, as well as our challenges.
Many of the activities involved in bringing our products to market have a direct impact on the environment.
It is everyone’s responsibility to seek to reduce that impact wherever possible. Every small step counts.

We must FOR MORE INFORMATION:

on L’ORÉAL’s policy on environmental stewardship, please
+ Implement L’ORÉAL’s commitment to read the “Targets 2020: Sharing Beauty with All”.
environmentally-friendly processes

+F
 avour the use of renewable raw materials and the
development of environmentally-friendly packaging
Who to contact: If you have a concern about
+C
 onsider how our behaviour in all aspects of our environmental stewardship, don’t keep it to
work impacts on the environment, so that we can yourself. Speak to your manager, your Health and
reduce that impact wherever possible: we can, for Safety Manager, your Human Resources Manager
example, contribute by cutting out unnecessary or your Ethics Correspondent; they will be able
travel, saving water and energy and avoiding to help and support you (see also the chapter on
generating waste. Where waste is unavoidable, we “I Have a Concern: Open Talk”).
must ensure materials are recycled or disposed of
in a responsible fashion. Even small gestures, such
as separating food waste in Company eating areas,
can make a difference

+T
 ake all necessary actions to prevent and stop
violations of L’ORÉAL’s environmental policy

+R
 eport immediately all spills or unusual emissions
to the air or water to our manager or our Health
and Safety Manager

We must not
- Ignore Company rules on environmental
stewardship

Ethical?
20.1 - The pollution control device on a critical piece
of manufacturing equipment is faulty. I’ve just learnt
it will take three days to obtain parts and make a
repair. Can we really afford to halt production when
we have a huge backlog of orders to fulfil?

We have no choice. Our commitment to environmental

good practice takes precedence over short-term profits
or production schedules. The machine must not be run
without the required pollution controls. You must notify
your management to help you work out a solution.

20.2 - As long as we comply with local law, why do

we have to follow L’ORÉAL’s environmental standards
if it puts us at a competitive disadvantage?

L’ORÉAL’s commitment to the environment goes

beyond simple legal compliance. If you feel that there
are competitive business issues at stake, you should
discuss these with your manager.

36
 The way we work

CONTRIBUTION
TO THE COMMUNITY
L’ORÉAL is a responsible stakeholder in society, a good neighbour and a concerned citizen committed to the
communities in which we do business. We encourage employees to play an active role in the community.

We must FOR MORE INFORMATION:

on L’ORÉAL’s contribution to the community, please read
+U
 nderstand that philanthropy is a long-term the “Targets 2020: Sharing Beauty with All”.
commitment. All actions, regardless of size, must be
engaged in with a clear plan of how to develop the
partnership over time

Who to contact: If you have a concern about

We must not contributing to the community, don’t keep it to
yourself. Speak to your manager, your Human
-E
 ngage L’ORÉAL in actions that do not reflect our Resources Manager or your Ethics Correspondent;
Ethical Principles and Group philanthropy strategy they will be able to help and support you (see also
the chapter on “I Have a Concern: Open Talk”).
-O
 blige employees or business partners to donate
gifts or funds to philanthropic projects supported
by L’ORÉAL

Ethical?
21.1 - A philanthropy programme that I am involved
with in my local community has asked if L’ORÉAL
can provide free products to support their cause. I’m
aware that there is a large quantity of shampoo and
bath gel that is going to be destroyed because it is
in the old packaging. I could arrange to have them
picked up without anyone knowing. Can I give it to
them?

L’ORÉAL wants to support you in your philanthropic

efforts, if they are in line with the Company’s strategy.
You should notify your manager, who can see if this
particular charitable cause is in line with L’ORÉAL’s
strategy, and propose it to the person responsible for
philanthropy in your country.

21.2 - The hospital at which I volunteer each week is

asking everyone to help recruit new volunteers, and
would like me to get L’ORÉAL more involved. I know
that several of my colleagues might be interested.
Should I speak with them directly?

If this hospital represents an opportunity in line with

L’ORÉAL’s overall philanthropy strategy, you should
speak to your manager to see if it would be possible
to engage the Company in a partnership with the
hospital. L’ORÉAL strives to “go beyond the cheque”,
and to develop partnerships which combine cash and
in-kind donations, but also employee contributions, and
especially sharing the expertise we have to help others.
You could be the corporate sponsor for this project,
and develop a meaningful long-term programme
together.

37
THE MANAGER’S
ROLE
As a Manager, you have an added responsibility because:
- you set an example and promote ethical conduct
- you are a decision-maker faced with more complex and difficult issues
- your team will come to you for advice and help

How to set an example How to answer your team’s questions

Beyond your daily behaviour, which must be Make sure you are aware of the Group’s various
exemplary, there are some simple gestures you can ethical policies. It is your responsibility to ensure your
make to show the importance that you give to ethics team knows about them. Also, take the time to listen
at L’ORÉAL, and namely: to your employees: it is rarely easy for them to bring
- Display the L’ORÉAL SPIRIT in your office up these types of questions.
- Always have the Code of Ethics at hand
- Never ask or even suggest to your team that they If you do not know how to answer their questions,
disregard the Code of Ethics you must direct them to the person who is best able
- Take time to explain the Code of Ethics to new to provide advice. Ethical issues are rarely simple, but
employees they should not be avoided.
- Find times during the year (and not only on Ethics
Day) to discuss ethical issues Which is more important for me as a Manager:
- Regularly reflect on the ethical dilemmas that could meeting my obligations on financial or business
arise in your work goals, or those set out in the Code of Ethics?
- Explain in detail the ethical competencies such as
“Act/Lead with Human Sensitivity” and “Obtain The two are perfectly compatible – and directly
Results with Integrity” during annual staff appraisals connected. Doing the right things for the right reasons
- As soon as you have the opportunity, recognise is always good business. The Company’s interests
and value an employee’s particularly ethical and are never served by unethical or unlawful business
courageous behaviour practices.

Your staff may also hesitate to come talk to you

about their ethical concerns and questions. You can Do Ethical Principles apply to all levels of
put them at ease by regularly telling them that you management, right to the very top?
are available to listen to their concerns and reminding
them that an employee who, in good faith, shares his Ethical Principles apply to everyone. The greater one’s
or her concerns shall not be subject to retaliation. responsibilities, the more one should have exemplary
behaviour. A double standard would be unacceptable
and contrary to L’ORÉAL’s ethics.
How to include ethics in your
decision-making process
When you have to make a decision, refer to the
questions found in the “How to Use This Code”
section. Remember that just because you have the
right to do something does not mean it is in line with
the Group’s Ethical Principles.

If you made a decision for ethical reasons, and

subject to our rules of confidentiality, share it
with your team so that they can benefit from your
knowledge and follow your example.

38
Published by:
SVP & Chief Ethics Officer
L’ORÉAL

Headquarters:
41, rue Martre
92117 CLICHY CEDEX
France

Registered Office:
14, rue Royale
75008 PARIS
France

http://ethics.loreal.wans
www.lorealethics.com

Photographs:
Stéphane de Bourgies, Stéphane Patti. All rights reserved.

Design:
www.meanings.fr