3 . Monitoring and control system in respect of  Human Rights Five audits were conducted within Group owned factories and distribution centres, covering all the Rules on Human Rights. (i) Child labour : none of the audits revealed any non- conformity of employment of a child under the age of 16. One audit revealed an intern working nights, a point that had been corrected at the time of the follow-up audit. As part of the annual ethics reporting in 2021, it was reported that: • 16 employe es were 16-18 years of age (1) ; and • 0 employee under 16  years of age worked in the Subsidiaries (ii) Forced labour : One audit revealed a case of employees of a subcontractor who should have been on permanent contracts instead of fixed-term contracts, following successive fixed-term contracts. Another audit revealed that outsourced workers were on fixed-term employment contracts that had expired, which had been corrected at the time of the follow- up audit. In the annual ethics reporting, no subsidiary declared the use of labour in a prison environment. (iii) Freedom of association : the audits did not reveal any cases of non-conformity. One audit revealed a case of a collective bargaining document that had not been sent to the competent public authorities due to the health crisis linked to Covid-19. (iv) Non-discrimination : the audits did not reveal any cases of non-conformity. (v) Working hours : one audit revealed insufficient rest time at one site and two audits revealed working hours in excess of 60 hours per week. (vi) Salaries and costs : one audit revealed an error in the calculation of mandatory social security contributions and a delay of more than one month in salaries being paid. Another audit revealed a case in which outsourced workers had not been paid enough for overtime they had worked, which had been corrected at the time of the follow-up audit. (vii) Sexual and psychological harassment : the audits did not reveal any cases of non-conformity. (viii) Health and safety : one audit revealed irregular evacuation and fire safety exercises as well as missing health and safety registration documents. Monitoring and control system in respect of  Health, Safety and the Environment In 2021, 83   “Top managers” (managers of factories or distribution centres, Management Committee members, etc.) attended the Leadership & Safety Culture seminar, held at the CEDEP, The European Centre for Executive Development, at the INSEAD campus in France. Since the start of this programme, 669   senior managers have been trained. The main objectives of these seminars are to raise awareness with top managers about safety issues, increase their leadership ability and see these behaviours adopted and maintained over the long term. 34 factories are certified ISO  45001, representing 87% of the Group’s factories. 34 plants are certified ISO  14001, representing 87% of the Group’s plants. In 2021, in the context of the Covid-19 health crisis: • 2 risk audits were performed on site; • 2 combined risk and EHS culture audits were performed on site; and • 2 combined Quality, Environment, Health, Safety and Performance audits were performed on site. The most frequently identified risks during EHS risk audits are related to fire protection, procedure safety, hazardous energies, containment of fire water runoff and wastewater management. The cases of non-conformity and formal notice were systematically subject to corrective actions. There were two neighbourhood complaints in 2021: one factory was the subject of a complaint about the release of an unpleasant odour related to wastewater being discharged from the site, and an administrative site was the subject of a complaint about the municipal storm water system overflowing during periods of heavy rain. This system passes through the site and, after a study conducted by the Syndicat Intercommunal d’Aménagement Hydraulique (the French inter-district planning authority), the under-sizing of the municipal system was identified as the most likely cause. There were 4 cases of non-conformity with environmental regulations notified by an administrative authority in 2021. They cover three sites and relate to the quality of wastewater (one site) and to the need to adapt some of the technical facilities (two sites). One fine was imposed in 2021 (China) amounting to RMB 190,000 (approximately €27,000): this is linked to non‑compliance regarding the quality of effluent discharged from the site. 3.4.7.3. Results of the application of the  plan to suppliers Adoption of the Applicable Rules by Suppliers 100% of strategic Suppliers in the direct purchases category and 78% of strategic Suppliers in the indirect purchases category have made a contractual commitment to comply with the Applicable Rules. All purchasers know the Applicable Rules and know which people to contact in the event of doubts. In 2021, 145 newly recruited purchasers in the Group received in-depth training in responsible purchases. Monitoring and control system The Applicable Rules are controlled through external audits. These audits cover questions on Human Rights as well as Environment, Health and Safety and cover all activities of the audited Site without being limited to the parts of the Site that operate for L’Oréal. 1,236 on-site audits were conducted in 2021, as part of regular audits, but also ad hoc audits following a risk analysis (40 ad hoc audits in 2021) (2) . Thus, 98% of Supplier production sites requiring audits were audited at least once. (1) The scope of consolidation of human rights data arising from ethics reporting is identical to that of social data. (2) Audits for which the Supplier is not part of the scope, but in respect of which the purchaser decided to conduct a social audit as a precaution. They represent 3% of the total number of audits. 156 L ’ ORÉAL I UNIVERSAL REGISTRATION DOCUMENT 2021 RISK FACTORS AND CONTROL ENVIRONMENT Vigilance Plan