4 Aware of the scale of the challenge throughout its entire value chain, L’Oréal has set ambitious goals to respect Human Rights with regard to the protection of personal data (see section 4.3.3.2. “L’Oréal’s commitment to protecting personal data”), the data of its consumers (see section 4.3.3.3. “Measures taken in favour of consumers”), its employees (see section 4.3.3.4. “Measures taken in favour of L’Oréal employees”), the employees of its suppliers (see section 4.3.3.5. “Measures taken in favour of the employees of the Group’s suppliers in the context of their working conditions”), local communities (see section 4.3.3.6. “Measures taken in favour of communities”) and women in particular (see section 4.3.3.7. “Measures for the promotion of women's rights” of this document), through various internal or public documents. Code of Ethics L’Oréal’s commitments to respecting and promoting Human Rights, with reference in particular to the 1948 Universal Declaration of Human Rights and the 2011 United Nations Guiding Principles on Business and Human Rights. Human Rights Policy L’Oréal’s commitments to its stakeholders, particularly its consumers and civil society, and which describes the way in which these commitments are fulfilled in practice. Employee Human Rights Policy In 2020, L’Oréal launched a specific policy on Employee Human Rights that undertakes to respect a base of universal Human and Social Rights for its employees, regardless of their position or location in the world. “The Way We Buy” A practical guide intended to specify the Group’s standards and to help employees handle situations that they might encounter in the performance of their duties in relationships with suppliers. Mutual Ethical Commitment Letter The Group’s suppliers must sign an ethical commitment letter that sets out its requirements and commitments to its suppliers. In 2021, the Group published an updated version, the Mutual Ethical Commitment Letter, which highlights the mutual commitment between it and its suppliers. This  document covers, in particular, Human Rights and working conditions. This new version is being rolled out gradually with all suppliers worldwide. (see section 3.4. “Vigilance Plan” of this document). “Suppliers/Subcontractors and Child Labour” Description of the main commitments concerning child labour by suppliers/subcontractors. L’Oréal’s Influencer Value Charter L’Oréal does not work with influencers under the age of 16 or the legal contractual age. Employee evaluation system The ethical competency “Acts with integrity and respects others” is included in the annual appraisal system for all employees. Speak Up policy L’Oréal’s Speak up policy, running since 2008, enables employees to report serious violations of Human Rights and Fundamental Freedoms, health and safety of people and respect for the environment, notably via a secure Internet site (ethics whistleblowing channel) directly to the Chief Ethics, Risk and Compliance Officer. The Group’s ethics whistleblowing channel (www.lorealspeakup.com) has also been accessible to all Group stakeholders since 2018. An annual ethics reporting system The system is used to monitor the implementation of the Ethics and Human Rights programme. The  subsidiaries are informed of their potential areas for improvement by the Global Ethics, Risk  & Compliance Department. 100% of the subsidiaries completed their annual ethics reporting in 2021. Procedures for prospective acquisitions When prospective acquisitions are being reviewed, the responses to the “Ethics and Human Rights questionnaire” submitted to target companies serve to identify whether they have properly taken into  account risks related to failure to respect Human Rights (abolition of child labour and compulsory and forced labour, etc.), among other issues. Raising employee awareness Ongoing communication The Group’s Human Rights policy and Employee Human Rights Policy is communicated to all Group employees. The Chief Ethics, Risk & Compliance Officer regularly visits the Group’s entities all over the world to meet employees at all levels of the Company. 100% of the subsidiaries have communicated on at least one Human Rights subject (1) . Training Specific training is being rolled out for the Management Committees. ● A specific, compulsory e-learning course on Ethics covering certain Human Rights themes is currently being rolled out in all subsidiaries. As of 31 December 2021, 76% of the employees with access to the online module had completed this course. ● In 2021, 145 purchasers were trained in responsible purchasing practices. This training is compulsory for any new purchaser. 100% of the Group’s subsidiaries included issues related to Human Rights in their local training programme. (1) The scope of consolidation of Human Rights data arising from the ethics reporting is identical to that of social data. L ’ ORÉAL I UNIVERS AL REGISTRATION DOCUMENT 2021 247 L’ORÉAL’S SOCIAL, ENVIRONMENTAL AND SOCIETAL RESPONSIBILITY Policies, performance indicators and results