L'Oréal - 2018 Registration Document

L’Oréal’s corporate social, environmental and societal responsibility POLICIES, PERFOR MANCE INDICATORS AND RESULTS

POLICY TO PREVENT CORRUPTION 3.3.4. Wishing to act in all circumstances in accordance with the ethical principles it has set itself and to comply with the laws and regulations in force in all the countries where it operates, the L’Oréal Group applies a zero tolerance policy in terms of corruption. A long-standing commitment at the highest level of the Company L’Oréal has been a member of the United Nations Global Compact since 2003 and supports the fight against corruption. The Group is committed to complying with the United Nations

Anti-Corruption Convention of 31 October 2003 and to applying all applicable laws, including the Sapin 2 law in France. This commitment is supported at the highest level of the Company by its Chairman and Chief Executive Officer who renews L’Oréal’s commitment to the United Nations Global Compact every year. L’Oréal is a member of the International Chamber of Commerce Anti-Corruption Commission and a member of Transparency International France.

3

The involvement of everyone in preventing corruption

The Executive Committee

Regularly reviews the corruption prevention policy presented to the Board of Directors.

The Director of Risk Management and Compliance

Reporting to the Chief Executive Officer, he is responsible for preparing and monitoring the corruption prevention programme. He leads corruption risk mapping.

They are responsible for the proper deployment of the corruption prevention programme and for compliance with the corruption prevention policy.

The Country Managers

They may contact their management, their Legal Director, their Administrative & Financial Director, their Internal Control Manager, their Ethics Correspondent or the Director of Risk Management and Compliance and, ultimately, the Senior Vice-President and Chief Ethics Officer, if they have any questions about compliance with this commitment. The aim is to ensure that all the situations encountered are thoroughly examined and, where applicable, that the appropriate steps can be taken.

Employees

L’Oréal’s Code of Ethics and the practical corruption prevention guides L’Oréal’s Code of Ethics publicly states a zero-tolerance policy on corruption which applies to all employees, corporate officers, Directors and members of the Executive and Management Committees of the Group and its subsidiaries worldwide. L’Oréal’s Code of Ethics was updated in 2014. Available in 45 languages, and in French and English in Braille, it is distributed to all employees worldwide. L’Oréal has also published a more detailed corruption prevention policy that is available on its website, loreal.com. With regard to employees, the Group also has other reference documents for the purpose of specifying the practices to be adopted and on corruption prevention: Specific corruption prevention Guide: rolled out throughout s the Group as a whole since 2013 and rounded out in 2018, it covers the relationships with each of L’Oréal’s stakeholders, in particular with the public authorities and intermediaries. This practical Guide is intended to specify the Group’s standards and to help employees to handle situations that they might encounter in the performance of their duties. It reaffirms L’Oréal’s corruption prevention policy which was approved by the Chairman and Chief Executive Officer and the Executive Committee and presented to the Board of Directors. This policy posted

online on L’Oréal’s website (www.loreal.com) restates the following principles:

the zero-tolerance policy on corruption, • the prohibition of facilitation payments, •

the prohibition of all contributions to political parties or • politicians with the aim of obtaining a commercial advantage, the prohibition on giving and accepting gifts and/or • invitations that might influence or be perceived as influencing a business relationship, communication of the commitment to preventing • corruption to the Group’s business partners, compliance with these commitments by intermediaries • or agents representing L’Oréal, particularly in countries where there is a high risk of corruption; Employee guide – Gifts/Invitations: distributed in 2014 on a s Group-wide basis to specify the rules in this regard; it is now integrated into the specific corruption prevention guide; The Way We Buy : a practical and ethical guide governing s the relationships between suppliers and all employees involved in purchasing decisions. This document has been translated into 12 languages.

REGISTRATION DOCUMENT / L'ORÉAL 2018

217