L'Oréal

The role of the administrative, management and supervisory bodies

Reference: page 193 (section 4.1.1).

The Board had 16 non-executive members, 1 executive member and 2 employee representatives in 2025 (2024: 15/1/2). Excluding directors representing employees, it was 40% women (2024: 43%) and 53% independent (2024: 50%).

"It has incorporated environmental, social and governance (ESG) skills into its diversity policy, and had 14 members with experience in this area in 2025." Three priority topics are identified: the role of the ESG strategy within an international group, governance and business ethics, and the Group's role in society (page 193).

Four committees carry the work (page 193):

• Strategy and Sustainability Committee – strategic orientations, decarbonisation and the L'Oréal for the Future programme, through regular presentations by the Chief Corporate Responsibility Officer.
• Audit Committee – "has overseen financial reporting as well as sustainability issues and sustainability risk management since 2018"; under the CSRD its remit was expanded to include "reviewing the double materiality assessment and monitoring the progress of the Sustainability Report at each of its meetings in 2025".
• Human Resources and Remuneration Committee – remuneration including the CEO's non-financial targets.
• Nominations and Governance Committee – governance, the diversity policy and directors' ESG skills.

Information provided to and sustainability matters addressed by the undertaking's administrative, management and supervisory bodies

Reference: pages 193-194 (section 4.1.1); page 206 (section 4.2.2).

"The Board of Directors ensures that it listens carefully to L'Oréal's stakeholders... It is regularly informed of the expectations of investors as expressed in roadshows following Group results publications, of the main non-financial rating agencies, and of its employees, notably through the Human Resources and Remuneration Committee and presentations by the Chief Human Relations Officer" (page 193).

Sustainability reaches the Board through the report on the interventions of the Chief Corporate Responsibility Officer, and diversity, equity and inclusion through the DEI Advisory Board's activity report (page 193). "The Board of Directors oversees the main material impacts, risks and opportunities for L'Oréal and the value chain..., which were examined in detail by the Board and its Committees in 2025" (page 194).

On outcomes, the Board "reviews annually the results achieved and the relevance, if any, of adapting the action plan or modifying the objectives" (page 193). For climate, "Each year, the Board of Directors reviews the outcomes of the climate strategy against the initial objectives", and in 2025 it received the conclusions of an in-depth review of the carbon pathway (page 206).

Integration of sustainability-related performance in incentive schemes

Reference: pages 112-114 (section 2.4.1.2.1), incorporated by reference; page 194.

Annual variable remuneration of the Chief Executive Officer splits 60% financial and 40% non-financial and qualitative. Inside the non-financial 25%: 10% CSR – L'Oréal for the Future programme, 7.5% Human Resources, 7.5% Digital development. The qualitative 15% covers Management and Image, Company reputation, stakeholder dialogue (page 112).

The L'Oréal for the Future criteria used to assess the executive corporate officer are named (page 113): "% of renewable energy use on operated sites and stores"; "% of recycled or reused water for industrial purposes in factories"; "% of sustainably sourced biobased materials used in formulas and packaging"; "% reduction in the use of virgin plastic for product packaging in absolute terms compared to 2019"; and the number of people from disadvantaged communities helped into employment.

Performance shares, granted to the CEO and more than 2,000 other recipients, split 80% financial and 20% non-financial, of which 15% CSR – L'Oréal for the Future (renewable energy, recycled or biobased packaging materials, recycled or reused water) plus gender balance in strategic positions, assessed over three full financial years with four-year vesting (page 114).

Statement on due diligence

Reference: page 272 (section 4.15.2).

The statement is a mapping of the five core elements of due diligence to sections of the sustainability statement:

For (d) the statement adds: "For each material negative impact, the remediation measures are explained in the second section (policy) and the third section (action plans) of the topic in question." For (e): "The monitoring of the effectiveness of these efforts is explained in the second section (policy), third section (action plans) and fourth section (quantitative results) of this report" (page 272).

GOV-4 is also listed among the datapoints derived from other EU legislation, referenced to SFDR (page 277).

Risk management and internal controls over sustainability reporting

Reference: page 155 (section 3.4), incorporated by reference into section 4.1.3 (page 271).

"The Chief Financial Officer is responsible for preparing the Group's sustainability information, with the support of the Sustainable Finance and Legal & Compliance departments. This information is reported to the Audit Committee, which is responsible for monitoring issues relating to sustainability information and the related risk management system on behalf of the Board of Directors" (page 155).

Definitions, scope and controls for each metric are documented in a single "Book of Norms for Sustainability Reporting", "a constant work in progress... continually enriched by the findings of risk assessments and internal control points identified in both internal reviews and external reviews" (page 155).

Three levels of control (page 155): Group experts in each function produce and report the data; the Sustainable Finance function "puts in place the reporting framework and information systems" and "supervises and monitors the reliability of the reporting by the entities in the Countries and Regions and at Group level"; and "the Internal Audit Department and Sustainability Auditors assess[] that the sustainability reporting system operates effectively".

Identification and assessment of sustainability risks "is integrated into the Group's overall risk management process" (page 197).

Strategy, business model and value chain

Reference: pages 24-25 (section 1.3.1) and pages 26-27 (section 1.3.2), incorporated by reference into section 4.1.

L'Oréal describes "a single business: beauty, nothing but beauty and all beauty", built on universalisation and singularisation, with the sense of purpose "Create the beauty that moves the world" and a dual objective of "economic and corporate excellence" (pages 24-25). Six strategic drivers are named: Research & Innovation and the Green Sciences programme, creativity, operational and safety excellence, Digital and Beauty Tech, multi-channel distribution, and sustainability goals (page 25).

The value chain runs across seven stages (pages 26-27):

• Research, Innovation and Technology – 725 patents filed in 2025, EUR 1,380m of expenditure (3% of sales), 22 cosmetic research centres, more than 4,300 employees in Research
• Design; Sourcing – 1,499 social audits conducted in 2025
• Factories and logistics hubs – 37 factories, 100% ISO 9001 and ISO 22716 certified
• Digital and marketing – 40 international brands, 79.2% of media investment digital, fourth largest advertiser worldwide
• Distribution channels – more than 7 billion products, 160 distribution centres
• Use and end-of-life – the 3Rs packaging approach

Value created in 2025 includes EUR 3.3bn of taxes and duties paid, nearly 45,000 employee shareholders and 25,000 job opportunities a year for people under 30.

Interests and views of stakeholders

Reference: pages 198-201 (section 4.1.3.2).

"In preparation for the implementation of the CSRD, in 2024, L'Oréal updated its double materiality assessment, a strategic exercise conducted with its stakeholders. More than 45 external partners – investors, NGOs, distributor customers, industry bodies and suppliers – and numerous internal experts took part in targeted interviews. These discussions were an opportunity to confirm findings, provide new perspectives and identify areas for improvement, which were then incorporated into the final analysis" (page 198).

Eleven stakeholder groups are tabulated with the purpose of dialogue and 2025 examples (pages 198-201), from shareholders, investors and rating agencies to distributors, local communities, the scientific community, consumers, students, suppliers, NGOs, public authorities and employees.

2025 examples include a strategic partnership with the Carrefour group signed at the Consumer Goods Forum; the #JoinTheRefillMovement global campaign on World Refill Day; Suppliers Days and the Spread the Green Vibes awards; Citizen Day, with 28,700 employees volunteering across 73 countries; more than 30,000 people logging on to Ethics Day sessions over 60 sessions; and 90% participation in the annual "Pulse" survey.

"Based on the results of this materiality assessment... the Group conducted a strategic review of the L'Oréal for the Future programme in mid-2025" (page 198).

Material impacts, risks and opportunities and their interaction with strategy and business model

Reference: page 202 (section 4.1.3.3); per-topic IRO tables at pages 205, 216, 223, 228, 232, 237, 247, 250, 255, 256, 258 and 259.

"The identification of material impacts, risks and opportunities (IROs), presented in this assessment, provides key information about L'Oréal's resilience in the face of sustainable development challenges. Their presentation is organised according to their materiality along L'Oréal's value chain. Each dedicated section begins with a detailed presentation of material IROs" (page 202).

The findings table lists thirteen topic blocks against the ESRS and the relevant chapter: climate change (E1, 4.2), pollution (E2, 4.3), water resources (E3, 4.4), biodiversity and ecosystems (E4, 4.5), resource use and circular economy (E5, 4.6), workforce (S1, 4.7), privacy and personal data protection (S1/S4, 4.8), human rights in the value chain and communities (S2/S3, 4.9), product safety (S4, 4.10), responsible labelling and consumption (S4, 4.11), responsible marketing and advertising (S4, 4.12) and business conduct (G1, 4.13). Every topical ESRS standard is material; none is excluded.

Materiality is mapped along a value chain running upstream (sourcing raw materials), through L'Oréal's own activities (Research & Innovation, production, design and marketing), to downstream (distribution, product use and end-of-life) (page 203).

Description of the processes to identify and assess material impacts, risks and opportunities

Reference: page 197 (section 4.1.3.1).

"In preparation for the implementation of the CSRD, L'Oréal updated its double materiality assessment in 2024 together with its stakeholders... The scope of the analysis covers L'Oréal Groupe in its entirety, i.e., all its entities and activities" (page 197). "Each dependency is systematically analysed to determine whether it represents a risk... or an opportunity".

Five steps (page 197): documentary analysis; identification of IROs "working with a specialist consultancy", categorised on the ESRS framework; assessment and rating using "a robust quantitative rating methodology... considering various time horizons (short term: 1 to 3 years; medium term: 3 to 5 years; and long term: beyond 5 years)", with financial materiality thresholds "aligned with the Group's risk mapping"; consultation with more than 45 external stakeholders; and validation by the Steering Committee, an expert committee, the Executive Committee and the Board through the Audit Committee.

2025 update: "In 2025, the assessment was deemed stable and confirmed the material issues identified" (page 197).

"The Task Force on Climate-related Financial Disclosures (TCFD) and Taskforce on Nature-related Financial Disclosures (TNFD) framework methodologies were used to carry out in-depth analyses on climate-related and nature-related issues" (page 197).

Disclosure requirements in ESRS covered by the undertaking's sustainability statement

Reference: pages 272-276 (section 4.15.3); pages 277-279 (section 4.15.4); page 271 (section 4.15.1).

Section 4.15.3 is a full content index mapping each disclosure requirement to a section, under the heading "Reference in L'Oréal's sustainability statement". It covers ESRS 2 (BP-1, BP-2, GOV-1 to GOV-5, SBM-1 to SBM-3, IRO-1, IRO-2) and every topical standard E1 to E5, S1 to S4 and G1.

Where no section is given, four markers appear:

• "Phased" – E1-9, E2-6, E3-5, E4-6, E5-6, S1-7 and S1-15
• "Not material for L'Oréal" – E1-8, S1-11, G1-3, G1-4 and G1-5
• "N/A" – E4-1 and E4-5
• for S4-5, "L'Oréal has not set a quantitative target for this topic"

Section 4.15.4 lists the datapoints derived from other EU legislation under ESRS 2 Appendix B; SBM-1 fossil fuel, chemical production, controversial weapons and tobacco involvement, and E1-1 paragraph 16(g) exclusion from Paris-aligned benchmarks, are all marked "Not material for L'Oréal" (page 277).

Section 4.15.1 lists information incorporated by reference (page 271): GOV-5 from section 3.4, SBM-1 workforce by geographical area from note 5 to the consolidated financial statements, the business model and value chain from sections 1.3.1 and 1.3.2, E1 GOV-3 remuneration criteria, E2-1 risk management, S1-14 health and safety audits and S2-4 social audit monitoring.

Transition plan for climate change mitigation

Reference: pages 206-209 (section 4.2.3); governance page 206 (section 4.2.2).

"L'Oréal has developed a climate transition plan whose pathway has been validated by the SBTi. This plan pursues two ambitions: by 2030, to reduce Scopes 1 & 2 emissions by 57% and Scope 3 carbon emissions by 28% for goods and services purchased by the Group, business travel, upstream transportation and distribution; and by 2050, to reduce overall emissions by 90%, with any residual emissions offset to achieve net zero." Reductions run against a 2019 baseline (page 206). "L'Oréal is not affected by the EU Paris-aligned benchmark exclusions" (page 206, footnote).

Approval: the plan is drafted with the functions and business lines, validated by the Executive Committee and presented to the Board (page 206).

Locked-in emissions: "L'Oréal also strives to minimise 'locked-in' emissions, linked to the depreciation of assets designed to emit carbon irreversibly, such as certain emergency power generators or cooling systems containing refrigerants... The risks associated with these locked-in emissions are considered to be limited and are not expected to compromise the Group's decarbonisation targets" (page 207).

Funding: "L'Oréal does not report the financial resources for the climate transition plan as a separate, isolated disclosure", and "the Group does not manage an isolated 'transition budget'" (page 209).

Identification of climate-related risks and scenario analysis

Back-filled from ESRS 2 IRO-1 as applied to climate (section 4.2.1.1, page 204) and the climate adaptation plan (section 4.2.4, page 209). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

L'Oréal "has used the Task Force on Climate-Related Financial Disclosures (TCFD) methodology as a basis for identifying the major climate issues" (page 204).

Scenarios (page 204). Key risks and opportunities for 2030 and 2050 were identified from "a proactive approach to risk identification", "an assessment of the impacts based on the 1.5°C and 3-4°C temperature rise scenarios (IPCC scenarios RCP 1.9 and RCP 8.5)", and "incorporation of political, economic, social, technological, environmental and legal factors (PESTEL analysis)". The 2030 and 2050 horizons fall within the long-term (beyond 5 years) horizon of the DMA.

Physical and transition risks are distinguished in the E1 IRO table (page 205). Transition: a sudden supplier-imposed carbon price rise, competition for innovative packaging materials, and the market risk of failing to meet demand for sustainable products. Physical: water scarcity and rising temperatures affecting demand, extreme weather threatening agricultural raw material supply, and disruption to external energy supplies.

No global average temperature projection is stated per scenario.

Resilience in relation to climate change

Back-filled from the climate adaptation plan (section 4.2.4, page 209) and the E1 IRO table (page 205). This disclosure requirement did not exist under the 2023 ESRS the report was prepared against.

L'Oréal presents no resilience analysis under that name. What it discloses is a three-part climate adaptation plan (page 209):

• Raw materials continuity plan – "L'Oréal is seeking to diversify its sources as swiftly as possible, not just when there are material threats, and to adapt production areas, seek alternatives and work with partners to develop more sustainable farming practices within the overall goal of building a resilient supply chain while guaranteeing product quality."
• Business continuity plan – "L'Oréal works proactively to protect its sites against extreme weather events. Its approach comprises three key stages: (i) analysis of climate scenarios, (ii) incorporation of results into site risk reviews and (iii) implementation of tailored adaptation plans, supplemented by targeted audits of infrastructure resilience if necessary."
• Product consumption continuity plan – water-saving products and technologies for consumers in water-stressed markets.

No quantified financial resilience assessment, no statement of areas of uncertainty and no assessment of the capacity to adjust or adapt over short, medium and long term is given.

Policies related to climate change mitigation and adaptation

Reference: pages 206-209 (sections 4.2.3 Climate transition plan and 4.2.4 Climate adaptation plan), per the content index (page 272).

The climate transition plan is the mitigation policy. Its 2030 ambitions, unchanged by the 2025 strategic review of L'Oréal for the Future, are to reduce absolute Scopes 1 & 2 GHG emissions by 57% and absolute Scope 3 emissions from purchased goods and services, upstream transportation and distribution and business travel by 28%, both against 2019, and to reach 100% renewable energy use on operated sites and stores – "This target was extended in 2025 to include the Group's stores" (page 204).

The climate adaptation plan (page 209) has three strands: a raw materials continuity plan built on source diversification and more sustainable farming practices; a business continuity plan protecting sites against extreme weather through climate scenario analysis, site risk reviews and tailored adaptation plans; and a product consumption continuity plan offering water-saving products in water-stressed markets.

Implementation runs through roadmaps for each business line, Division and Region, "transposing the Group's net zero strategy to local scale", with priority actions carrying "quantitative time-bound targets" and support from the Sustainability Leaders Network (page 206).

Actions and resources in relation to climate change policies

Reference: pages 207-209 (sections 4.2.3.2 and 4.2.3.3); page 209 (section 4.2.4).

Scopes 1 & 2 actions (page 207): improving the energy efficiency of operated sites, reaching 100% renewable energy use on operated sites and stores, and continuing to electrify the vehicle fleet. "In 2025, L'Oréal hit a historic milestone by reaching 100% renewable energy use on operated sites and stores" (page 206).

Scope 3 actions (page 208), by lever: packaging (reduce weight, increase reusable and refillable formats, raise recycled content, engage suppliers); formulas (plant-based ingredients replacing petrochemicals, replace carbon-intensive ingredients, combat deforestation); digital marketing (reduce and reuse advertising content); point-of-sale promotions (environmental design, lighter monomaterial displays, lower power consumption); logistics (substitute air freight with sea and rail, multimodal transport, fill rates, lower-emitting engines and fuels); and business travel through a dedicated travel policy.

Resources. "The Group does not manage an isolated 'transition budget,' as these investments are inseparable from 'business as usual' operations. While certain specific expenditures can be identified as purely transition-related, they represent a non-significant amount on a Group scale" (page 209).

Targets related to climate change mitigation and adaptation

Reference: page 210 (section 4.2.5.1); milestone columns page 211.

"Compared with the ambition published in 2024, the scope of this objective has been extended to include operated stores that hold an electricity subscription" (page 210).

The GHG inventory carries explicit milestone columns (page 211): Scopes 1 & 2 market-based 68,456 tCO2eq in 2030; material Scope 3 3,556,054 tCO2eq in 2030; total GHG emissions 637,902 tCO2eq in 2050.

The pathway was "validated by the SBTi based on the Corporate Net Zero Standard in 2024" (page 196), and the decarbonisation targets "were not changed during the strategic review of the L'Oréal for the Future programme in 2025" (page 204).

Energy consumption and mix

Reference: page 210 (section 4.2.5.2); intensity page 211.

Within the fossil total, coal and coal products fell from 4,171 MWh to nil and natural gas from 32,419 MWh to 1,704 MWh, crude oil and petroleum products were 458 MWh, and purchased electricity, heat, steam and cooling from fossil sources fell from 65,336 MWh to 40,695 MWh (page 210).

Energy intensity from activities in high climate impact sectors was 23 MWh per EUR m of net revenue, unchanged on 2024. "The Group's activities are classified under NACE code C20.4 (Manufacture of soap and detergents, cleaning and polishing preparations, perfumes and toilet preparations)" (page 211).

Gross Scopes 1, 2, 3 and Total GHG emissions

Reference: pages 211-212 (section 4.2.5.3).

Material Scope 3 splits into purchased goods and services 4,743,254, upstream transport and distribution 335,678 and business travel 95,309. Other Scope 3 totals 1,180,810, including end-of-life treatment of sold products 437,594, use of sold products 237,445 and capital goods 164,303 (page 211).

GHG intensity was 149 tCO2eq per EUR m location-based and 146 market-based (2024: 159 and 155). Biogenic carbon outside Scope 1 was 67,992 tCO2eq. Renewable power purchased was 551,613,983 kWh: 10% PPAs, 55% bundled and 35% unbundled Energy Attribute Certificates (page 212).

Use of sold products "only includes direct emissions"; indirect use-phase emissions of 4,359,058 tCO2eq "are not included because they are considered optional by the GHG Protocol" (page 211).

GHG removals and GHG mitigation projects financed through carbon credits

Reference: page 212 (section 4.2.5.4).

"Although the cosmetics industry has a low carbon footprint compared to other industries, L'Oréal is focusing its efforts on decarbonising the value chain. The Group does not currently use carbon offsetting mechanisms and relies on biodiversity to capture carbon" (page 212).

The disclosure is therefore a nil return on carbon credits, given alongside the removals vehicle L'Oréal does operate: "In 2020, the Group launched the L'Oréal Fund for Nature Regeneration. Endowed with EUR 50 million, its mission is to restore one million hectares of ecosystems by 2030, with the overall goal of capturing 15 to 20 million tonnes of CO2 and creating jobs in the process", with the footnote that "The impacts in terms of CO2 and job creation will be measured and published once the projects have reached maturity" (page 212). At 31 December 2025 investments in the Fund totalled EUR 25.3 million against the EUR 50 million target (page 231).

Offsetting is deferred to the 2050 horizon: "Offsetting through carbon capture will be rolled out to deal with any residual emissions (up to a maximum of 10%), gradually ramping up through to 2050" (page 207).

Policies related to pollution

Reference: pages 217-220 (section 4.3.2).

"L'Oréal's material pollution issues concern air and water. Air pollution is identified as material both in the upstream value chain and within the Company's own operations. Water pollution is considered to be material throughout the value chain" (page 217).

A Responsible Water Use policy was published in April 2025: L'Oréal "is aiming to minimise the impact of its products and operations on water quality. This includes continuously raising the quality of wastewater discharged from its factories, working on improving the biodegradability of ingredients and formulas..., eliminating microplastics and reducing Substances of Very High Concern (SVHC), in particular by prohibiting the inclusion of any new ingredient classed as SVHC from the raw materials portfolio" (page 217).

The framework policy is deployed through three value chain policies (page 217): the EHS policy for operations, with an EHS management system, an ISO certification programme for production facilities and "an internal and external audit system covering all sites worldwide"; the Sustainable Purchasing Policy for upstream pollution; and the Research & Innovation policy for downstream pollution, built on the SPOT eco-design tool and on formula biodegradability assessed against OECD 301 or equivalent ISO standards.

Actions and resources related to pollution

Reference: pages 220-221 (section 4.3.3).

Water (page 220): "Each facility is equipped with a monitoring system for real-time tracking of regulated indicators, such as COD, pH and effluent temperature, as well as substances that could disrupt treatment facilities. This system not only detects the risk of overshoots, but also prevents any breaches in compliance and triggers the necessary corrective actions." Sites run annual self-assessments and internal audits, and the Waterloop concept improves treatment and recycling capacity.

Air (page 220): "the largest consumers are required to quantify their NMVOC emissions using a Solvent Management Plan, which includes an action plan to reduce air emissions." The plan is revised annually at the most exposed facilities, "covering more than 90% of solvents used".

Upstream (page 221): suppliers signing the Mutual Ethical Commitment Letter "undertake to put in place systems to prevent accidental pollution of the air, soil, surface and ground water during production and storage processes, including wastewater, as well as pollution during transportation". Specific third-party EHS audits apply to subcontractors handling aerosols, bleaching powders or flammable products.

Downstream (page 221): improving product environmental profiles through SPOT, improving formula biodegradability, removing microplastics and reducing substances of (very high) concern.

Targets related to pollution

Reference: page 219 (section 4.3.2.1.4 Treating industrial effluent), per the content index (page 273).

The pollution target L'Oréal reports is an internal effluent quality standard rather than a L'Oréal for the Future ambition: "In addition to these requirements, L'Oréal has defined an internal standard of 1,000 mg COD per litre of effluent, which is used to monitor the efficiency of its water treatment plants. This standard defines the maximum concentration of chemically oxidisable organic matter for its discharges. It was defined based on analyses of data on internal performance and the most modern wastewater treatment plants and of the rates observed in domestic water" (page 219).

The threshold is applied from the design stage of new capacity: "L'Oréal emphasises achieving the internal objective of limiting COD to 1,000 mg per litre of effluent, starting from the design phase of Waterloop projects, in order to achieve the trajectory defined by the Group" (page 220).

No quantified reduction target is set for NMVOC emissions, microplastics or substances of very high concern. The general rule applies: "The absence of a quantified target in the 'Outcomes' part of a sub-section of this report indicates that L'Oréal does not define any such target for this topic. It reserves the right to do so at a later date" (page 262).

Pollution of air, water and soil

Reference: page 222 (sections 4.3.4.1 and 4.3.4.2); scoping page 216.

L'Oréal scopes E2 narrowly and explains why: "the double materiality assessment concerning ESRS E2 on pollution has a more targeted approach than other standards owing to the list of pollutants in the European Pollutant Release and Transfer Register (E-PRTR)... Only pollutants exceeding the regulatory materiality thresholds are classified as material" (page 216). Pollutants prohibited in cosmetics, absent from raw materials or present well below classification thresholds were excluded; the remainder were quantified using L'Oréal's internal tool, data from the non-profit Citepa and conservative assumptions.

Two pollutants pass that filter: chemical oxygen demand (COD) for water and non-methane volatile organic compounds (NMVOCs) for air (page 216).

NMVOC emissions rose while COD fell. No soil pollution metric is reported; soil is not among the material E2 sub-topics, which are pollution of air, pollution of water, substances of concern, substances of very high concern and microplastics (page 202).

Substances of concern and substances of very high concern

Reference: page 222 (section 4.3.4.3); limitation at page 262.

"The same substance may be classified in several risk classes, which explains why the total quantity of substances of very high concern may be less than the sum of each class" (page 222).

Substances of concern are not quantified. The methodological notes list E2-5 among the information that could not be estimated: "the absence of sector-specific recommendations on data regarding substances of concern related to L'Oréal's activities makes it difficult to publish information comparable with the Company's peers. L'Oréal will work on gathering this information with a view to publishing it in the future, within the limits of that required by law" (page 262).

L'Oréal "prohibits the introduction of new ingredients classified as SVHC in its product portfolio" and "strives to remove from its products any substance which, although not classified as SVHC when the formula was first marketed, has subsequently been identified as such" (page 221).

Policies related to water and marine resources

Reference: pages 223-225 (section 4.4.2).

"The recently updated Responsible Water Use policy, published in 2025, forms the basis of its water management initiatives and recognises access to water as a fundamental human right... L'Oréal aims to achieve operational excellence in water management at operated sites, to engage suppliers and small producers in the upstream value chain in resource restoration programmes, and to respond to increasing constraints for consumers located in water-stressed areas downstream of its value chain" (page 223).

The policy is organised by value chain stage:

• EHS policy for water management at operated sites (page 223) – "Through the innovative Waterloop concept, L'Oréal is aiming to use recycled and reused water in industrial processes", with a 2030 objective of 100% recycled or reused water for industrial purposes at its factories. "Waterloop equipment and best practices are being deployed by order of priority of the water situation in the catchment basins in which L'Oréal operates."
• Sustainable purchasing policy (page 224) – promoting responsible water use by strategic suppliers, particularly in sectors with a high potential impact on water resources.
• Research & Innovation policy (page 225) – reducing the water footprint of formulas, assessed through SPOT, which covers water scarcity and water quality among its 14 impact factors.

Actions and resources related to water and marine resources

Reference: pages 225-226 (section 4.4.3).

Three action strands are set out (page 225): water resource preservation at operated sites, through deployment of Waterloop recycling and reuse equipment prioritised by the water situation of the catchment basins in which L'Oréal operates; working with upstream agriculture, engaging suppliers and small producers in responsible water use; and reducing the water footprint of formulas and of product use downstream.

The Group is "developing projects to regenerate catchment basins where it sources priority raw materials and its industrial operations are located, in order to preserve and restore the health of ecosystems and water resources" (page 223).

Downstream, the product consumption continuity plan applies: "the Group is innovating with formulas that use less water or that do not require rinsing. L'Oréal is also investing in innovations such as the L'Oréal Water Saver showerhead, which reduces water consumption in hairdressing salons" (page 209).

Design-stage control runs through SPOT, "which assesses the environmental footprint of products throughout their life cycles... 14 impact factors at each stage of the life cycle, from ingredients to use and recycling", including water use (water scarcity) and water quality (freshwater ecotoxicity, freshwater and marine eutrophication) (page 226).

Targets related to water and marine resources

Reference: page 227 (section 4.4.4.1).

Both targets sit in the "Safeguarding nature" pillar and survived the 2025 strategic review of the L'Oréal for the Future programme (page 196).

The second target's scope is defined in the methodological notes: "Water-stressed markets are defined as L'Oréal country subsidiaries with high projected water resource risks up to 2030", assessed on physical, regulatory and reputational risk using the WWF Water Risk Filter, itself based on the WRI Aqueduct Water Risk Atlas. "A market is therefore considered to be under water stress if it meets at least one of the following criteria: physical risk (BPH) ≥ 3; regulatory risk (BRG) > 3.4: Reputational risk (BRP) > 3.4" (page 269).

The recycled and reused water target is one of the criteria in the CEO's annual variable remuneration and in the performance share plan (pages 113-114).

Water consumption

Reference: page 227 (section 4.4.4.2).

Water intensity: total water consumption per net sales on own operations was 22 cu.m per EUR m, unchanged on 2024 (page 227).

Total consumption fell while recycled and reused water rose. Consumption in areas at water risk rose, but the report notes that this indicator is "calculated on the Group factory scope. This scope was defined in 2025 as described in the notes on methodology" (page 227), so the movement is not on a like-for-like basis.

Water withdrawal is a material sub-topic alongside water consumption (page 202), but no separate withdrawal or discharge volume is published. Section 4.4 is scoped to "the quantities of water withdrawn and used", with water quality and pollution dealt with under ESRS E2 and impacts on biodiversity under ESRS E4 (page 222).

Policies related to biodiversity and ecosystems

Reference: page 228 (section 4.5.2).

"The Sustainable Land Use Policy, published in April 2025, contains the guiding principles for L'Oréal's approach to land management and nature conservation. The policy is aligned with the principles of the conservation hierarchy (Avoid, Minimise, Restore and Rehabilitate, and Offset) and aims to transform the Group-wide systems on which L'Oréal's value chain depends. It is based on actions seeking to regenerate the health of ecosystems" (page 228).

Three further policies are named in the E4 IRO table (page 228): the Sustainable Purchasing Policy, the Forest Policy and the L'Oréal Fund for Nature Regeneration.

The exposure the policies address is set out at page 227: "The Group's supply and innovation strategy covers more than 1,500 raw materials sourced from 350 botanical species grown in more than 100 countries."

L'Oréal "actively participates in the work of leading international bodies, such as the Taskforce on Nature-related Financial Disclosures (TNFD), the Science Based Targets for Nature (SBTN) network, CDC Biodiversité's B4B+ Club, as well as the One Planet Business for Biodiversity (OP2B) collective" (page 228). The TNFD methodology was used in the double materiality assessment for nature-related issues (page 197).

Actions and resources related to biodiversity and ecosystems

Reference: pages 229-231 (section 4.5.3).

Restoring and regenerating biodiversity (page 231) has two strands. Regenerative farming among suppliers rests on four actions: "protecting and enhancing biodiversity on and around farms; supporting suppliers and farmers in implementing regenerative farming practices that restore soil structure and moisture; strengthening the resilience of crops and nature, while reducing the use of pesticides and chemical fertilisers; and supporting the livelihoods of agricultural communities". A named pilot runs in Indonesian palm plantations with local stakeholders and the research centre CIRAD. Supporting the regeneration of natural ecosystems uses nature-based solutions "in priority landscapes linked to the Group's most significant raw materials and production sites... to restore degraded land, such as peat bogs, located close to productive land, and to conserve ecosystems that are still intact".

Resources: the L'Oréal Fund for Nature Regeneration aims "to help restore one million hectares of ecosystems by 2030, capture 15 to 20 million tonnes of CO2 and create hundreds of jobs. Since 2020, more than one hundred projects have been reviewed... At 31 December 2025, investments totalled EUR 25.3 million, out of a total target of EUR 50 million" (page 231).

Targets related to biodiversity and ecosystems

Reference: page 231 (section 4.5.4.1).

On the third target the report adds that the rate "reflects its operational deployment without affecting the definitive measurement of the desired ecological impact", and that "The published performance is based on data for 2024, due to the time required to collect and consolidate all data" (page 231).

The regeneration metric is defined at page 269: the denominator is "the footprint in hectares related to the land cover of 15 priority raw materials... and the land footprint of the Group's industrial sites"; the numerator is "the number of hectares regenerated through biodiversity conservation projects and regenerative farming and sustainable purchasing projects, as well as the number of hectares linked to biodiversity programmes developed in the catchment basins in which the Group's production sites are located".

The sustainably sourced biobased materials target is one of the criteria in executive remuneration (page 113).

Policies related to resource use and circular economy

Reference: page 233 (section 4.6.2).

"In April 2025, L'Oréal published the Environmental Product Design policy, which sets out the Group's guiding principles in that area. L'Oréal aims to ensure that decisions related to product design are informed by environmental science, using Life Cycle Assessment as the benchmark for product's environment impact assessment... Beyond minimising the resource use and maximising the circularity of ingredients and packaging, to ensure transparency and build consumers' trust, marketing claims are grounded in evidence-based science" (page 233).

It is broken down into three policies (page 233):

• Circular Packaging policy, overseen by the Sustainable Packaging Department under Operations and framed by the 3Rs: "reduce: cut packaging intensity, mainly through lightweighting and reuse; replace: use alternatives, such as recycled or low-carbon impact materials; and recycle: design packaging compatible with recycling circuits".
• Research & Innovation policy for formulas, which prioritises ingredient biodegradability because "the environmental impact of formulas is mainly assessed at the end of the product's life cycle, with a focus on their interaction with ecosystems, notably aquatic environments".
• EHS policy to reduce and recycle waste from operated sites, "within the broader ambition of zero waste to landfill".

Actions and resources related to resource use and circular economy

Reference: pages 233-235 (section 4.6.3).

Packaging (pages 233-234) has four strands: reducing packaging intensity through lightweighting and refillable formats; using recycled or biobased materials, with social audits of recycled plastics suppliers in high-risk countries; promoting refillable, reusable and recyclable packaging by "gradually eliminating elements that interfere with recycling, such as certain opaque materials and metal components in plastics"; and developing collection and recycling channels with governments, suppliers, distributors and consumers, "particularly in countries where the relevant infrastructure remains underdeveloped".

Formulas (page 234): transitioning raw materials away from petrochemicals, the Green Sciences programme, and partnerships with biotech start-ups.

Waste at operated sites (pages 234-235): reducing waste at source; reuse and recycling driven by waste mapping, employee training and partnerships with waste treatment companies; and, since 2017, "the ambition of 'zero waste to landfill' for all its sites (unless required by regulations)".

Resources: the Circular Innovation Fund, set up at the end of 2020, completed fundraising at the end of 2023 "with EUR 111 million raised and 12 co-investors. As the primary sponsor of the CIF, L'Oréal pledged to invest a total budget of EUR 50 million in this Fund" (page 235).

Targets related to resource use and circular economy

Reference: page 235 (section 4.6.4.1).

The packaging intensity target "specifically covers primary and secondary packaging for products manufactured by the Group" (page 233).

Two of the three feed executive pay: the virgin plastic reduction is one of the L'Oréal for the Future criteria in the CEO's annual variable remuneration (page 113), and the recycled or biobased packaging materials percentage is one of the criteria for granting performance shares (page 114).

No quantified target is set for waste or for resource inflows. The general rule applies: "The absence of a quantified target in the 'Outcomes' part of a sub-section of this report indicates that L'Oréal does not define any such target for this topic. It reserves the right to do so at a later date" (page 262).

Resource inflows

Reference: page 236 (section 4.6.4.2).

Packaging tonnage fell while formula tonnage rose. Recycled packaging components rose from 26% to 33% of packaging weight, while the biobased and sustainably sourced share of packaging materials slipped from 11% to 10%.

Method (page 269): "The calculations for packaging are based on the packaging and production item specification systems, while the calculations for raw materials are based on the formula specification system. The formulas are broken down into raw materials."

Resource outflows

Reference: page 236 (section 4.6.4.3).

Recyclability of packaging improved by six percentage points, while the non-recycled share of waste rose by three points.

No separate durability or reparability figure is given for products themselves; the recyclability metric is scoped to packaging, consistent with the material sub-topic "Resource outflows: formulas and packaging" (page 202).

The design mechanism behind the recyclability figure is the 3Rs packaging strategy – "recycle: design packaging compatible with recycling circuits" – and the gradual elimination of "elements that interfere with recycling, such as certain opaque materials and metal components in plastics" (pages 233-234). Since 2018 L'Oréal has shared its SPOT packaging methodology through the SPICE (Sustainable Packaging Initiative for CosmEtics) initiative, which "has more than 30 international members" (page 234).

Waste

Reference: page 236 (section 4.6.4.3, waste table).

Total waste fell and waste sent to landfill fell to 221 tonnes, consistent with the "zero waste to landfill" ambition pursued for all sites since 2017 "unless required by regulations" (page 235). Recycling fell from 109,777 to 98,482 tonnes while energy recovery rose from 42,430 to 46,600 tonnes, so recovery shifted from material to energy.

Waste from operations is a material E5 sub-topic (page 202). Actions are the EHS waste policy, waste mapping, employee training on sorting at source, partnerships with waste treatment companies and a Group procedure for industrial sludge (pages 234-235).

Policies related to own workforce

Reference: pages 239, 241-242 (sections 4.7.2.1, 4.7.3.1, 4.7.4.1).

Social dialogue, freedom of association and collective bargaining (page 239): L'Oréal draws on "the Universal Declaration of Human Rights, ILO conventions, OECD Guidelines for Multinational Enterprises and the United Nations Guiding Principles on Business and Human Rights". The Executive Director of Labour Relations and Social Innovation ensures elections are held "without interference", that representatives have access to premises and employees, and that "alternative forums for dialogue are available in countries where freedom of association is restricted".

Living wage policy (page 239): "L'Oréal guarantees that all employees are paid a minimum wage in accordance with local laws and collective bargaining agreements. It also ensures that salaries are living wages and cover basic needs linked to housing, healthcare, food and education."

Health and safety policy (page 239): part of the EHS strategy, "making the health, safety and well-being of employees and suppliers non-negotiable priorities".

Diversity, equity and inclusion policy (page 242), owned by the Global Chief Diversity, Equity & Inclusion Officer, covers socio-economic and multicultural diversity, disability, age and generations, and gender equity and LGBTQIA+ inclusion. An equal pay HR policy aims "to limit unjustified gender pay gaps to within a range of 5% above and below".

Processes for engaging with own workforce and workers' representatives about impacts

Reference: page 239 (section 4.7.2.1.1).

"L'Oréal ensures that workers' representatives can operate effectively in all of its host countries, even where union rights are limited. The Group maintains dialogue with workers' representative bodies in the majority of its subsidiaries in Europe, Asia, Africa and the Americas" (page 239).

"Since 1996, a collective bargaining agreement has been in place between L'Oréal and the European trade unions. This led to the creation of the European Works Council, which has 30 members representing 26 countries. This body provides a platform for ongoing dialogue with General Management regarding the Group's challenges" (page 239).

Accountability sits with the Executive Director of Labour Relations and Social Innovation, who reports directly to the Chief Human Relations Officer (page 239).

Group-wide listening runs through "events such as the annual Ethics Day alongside regular town halls... In addition, an annual PULSE survey is carried out, collecting feedback from employees on their experience working for the Group" (page 239). 90% of those invited took part in 2025 (page 201). The Pulse Self-ID module lets employees "voluntarily share certain aspects of their identity while remaining anonymous" (page 242).

The Group's Social and Economic Committee is notified each year of the assessment and the sustainability report (page 197).

Processes to remediate negative impacts and channels for own workforce to raise concerns

Reference: page 238 (section 4.7.1.2); page 242 (section 4.7.4.1.3); page 260 (section 4.13.2.1).

"The Group has set up various channels that employees can use to raise concerns or report breaches of Group policies in complete confidence. These include the reporting line, the Speak Up platform – a secure, anonymous website with a system on hand around the clock and available in 30 languages (www.lorealspeakup.com) – and the network of designated people authorised to receive reports" (page 238).

"Employees are informed of the existence of the Speak Up programme, in particular through an e-learning course on ethics and human rights that is available and compulsory for all of the Group's new hires, as well as through awareness-raising initiatives such as the annual Ethics Day. These mechanisms are designed to ensure fair and confidential treatment and protection from retaliation... Any allegations expressed in good faith are examined in detail and adequate remediation measures are taken, if applicable" (page 238).

Reports reach the Chief Ethics, Risk and Internal Control Officer, and L'Oréal "undertakes to conduct an independent and impartial investigation into each report, followed by remediation if necessary" (page 260). On violence and harassment the Group "strives to ensure that all complaints... are dealt with diligently, confidentially and impartially" (page 242).

Taking action on material impacts on own workforce

Reference: pages 239-243 (sections 4.7.2.2, 4.7.3.2, 4.7.4.2).

Social dialogue (page 239): "Each year, collective bargaining agreements are signed with workers' representatives... In 2025, 27 industrial sites underwent a human rights audit (including freedom of association at 26 sites) by expert external auditors. In the event of a failure to comply, a remediation plan is put in place and the site is audited again... by the same specialist independent external auditor."

Living wages (page 239): "In 2025, for the third year in a row, the Group was certified globally by the NGO Fair Wage Network as a 'Living Wage Employer'... This commitment includes an annual inflation review and, where necessary, an adjustment to align wages."

Health and safety (pages 239-240): transparent accident reporting, risk analysis "using tools such as the Global Hazard Assessment Procedure (GHAP) and the Safety Hazards Assessment Procedure (SHAP)", the MESUR programme of structured manager-employee site visits, and targeted programmes including LIFE, Safe@Work-Safe@Home and Road Safety.

Work-life balance and training (page 241): at least 14 weeks' maternity or primary parent leave on full salary, at least six weeks' paternity leave, three days' paid carer's leave, remote working up to two days a week; "Job Musts", future-skills courses through L'Oréal University and personalised plans under the CONNECT process.

Targets related to own workforce

Reference: pages 239-240 (section 4.7.2.2.3); pages 242-243 (sections 4.7.4.1.2 and 4.7.4.2.1).

Health and safety. "L'Oréal's vision aims for a zero-accident environment, as the Company firmly believes that all accidents can be avoided. Its goal for 2030 is to have an enlarged Total Incident Rate (eTIR) of less than 0.6 at its operated sites." Action plans are defined and adjusted annually "to keep the rate of recordable work-related accidents below 0.6 by 2030", and "the Group has set the ambitious goal of cutting the number of accidents by almost 50% versus the current year" (pages 239-240). The 2025 outturn was an eTIR of 1.37, against 1.46 in 2024 (page 246).

Diversity, equity and inclusion. The Group has "an annual goal to maintain a proportion of women and men employees that may not be less than 40% in strategic positions", and an annual objective "of recruiting at least 20% of talent under the L'Oréal SeedZ Management Trainee Programme from non-partner schools and universities" (page 243).

Equal pay. "L'Oréal aims to limit unjustified gender pay gaps to within a range of 5% above and below" (page 242).

No target is disclosed for training hours, collective bargaining coverage or adequate wages, and the "minimum target for the number of employees with disabilities in all countries" (page 242) is not quantified.

Characteristics of the undertaking's employees

Reference: pages 244-245 (section 4.7.5.1).

Total workforce 97,583 in 2025, up from 95,023 – "The increase in the total number of employees in 2025 compared with 2024 is mainly due to the integration of the Aesop brand" (page 244).

Countries with at least 50 employees representing at least 10% of the total: France 17,582, United States 13,862, China 15,628 (page 244).

By contract type, 79,033 permanent and 18,550 temporary staff; non-guaranteed hours employees totalled 930, of whom 664 women (page 244). Permanent employees leaving the company numbered 10,470, a turnover rate of 13.5% (2024: 9,862 and 12.9%) (page 245).

Scope (page 269): a "month-end workforce at 31 December" covering "all L'Oréal employees, including non-active employees (in particular those on long-term sick leave, notice of departure, early retirement, extended unpaid leave), as well as interns and apprentices". The comparable statutory workforce is published in note 5.1 to the consolidated financial statements.

Collective bargaining coverage and social dialogue

Reference: page 245 (section 4.7.5.2).

L'Oréal reports collective bargaining coverage and workplace representation as banded percentages rather than figures. Both tables are limited to "Employees in the European Economic Area (EEA) (for countries with more than 50 employees representing over 10% of total employees)", which resolves to the Total European Economic Area and France, against bands of 0%-19%, 20%-39%, 40%-59%, 60%-79% and 80%-100% (page 245).

The restriction is explained in the methodological notes: "L'Oréal publishes the metrics concerned for member countries of the European Economic Area in accordance with the transitional provisions" (page 269).

No coverage rate is given for employees outside the EEA, and no figure is published for the percentage of employees covered by workers' representatives outside the EEA.

Context sits in the policy section: the European Works Council created under the 1996 collective bargaining agreement with the European trade unions has 30 members representing 26 countries, and the Group "maintains dialogue with workers' representative bodies in the majority of its subsidiaries in Europe, Asia, Africa and the Americas" (page 239).

Diversity metrics

Reference: page 245 (section 4.7.5.3).

The share of women in key strategic positions slipped one point to 48%, against the Group's annual goal that the proportion of women and men in strategic positions "may not be less than 40%" (page 243).

"Strategic positions" are defined at page 269 as, in the main, participants in the Business Review meeting: Executive Committee members including the CEO, directors reporting directly to the CEO, Region and Region Division General Managers, country or cluster General Managers, International Brand Directors and members of Division, Region, Corporate Research & Innovation and Functional Department Management Committees.

Adequate wages

Reference: page 245 (section 4.7.5.4).

The figure is supported by external certification: "In 2025, for the third year in a row, the Group was certified globally by the NGO Fair Wage Network as a 'Living Wage Employer', demonstrating that its employees are paid more than the local living wage defined by the NGO. This commitment includes an annual inflation review and, where necessary, an adjustment to align wages with the local cost of living. In this context, L'Oréal is aiming to have its certification renewed regularly" (page 239).

The Fair Wage Network is described as an "International NGO which provides the Group with a database on living wages in 200 countries" (page 239).

The underlying commitment, made in the Employee Human Rights policy in 2020 and reiterated in Share & Care, is that salaries "are living wages and cover basic needs linked to housing, healthcare, food and education" (page 239). Adequate wages is a material S1 sub-topic (page 202). No country-level breakdown is given.

Persons with disabilities

Reference: page 245 (section 4.7.5.5).

The figure is reported for the Group as a whole, with no gender split.

The methodological notes set out the limits of the number: "Disability data are based on individual reporting and therefore depend on local legislation and cultures. Some countries do not yet report people with disabilities, as the cultural environment may prevent people from declaring their disability" (page 269).

Disability sits inside the diversity, equity and inclusion policy pillar on "disability and physical, mental and social well-being: accelerate the inclusion of people with disabilities, by addressing both visible and invisible disabilities, mental health, chronic illnesses and neurodiversity, with a minimum target for the number of employees with disabilities in all countries" (page 242); that minimum target is not quantified in the report.

L'Oréal reports being recognised as a "Best Place to Work for Disability Inclusion" in several countries in the 2025 Disability Index (page 242).

Training and skills development metrics

Reference: page 245 (section 4.7.5.6).

No 2024 comparative is published for training hours, and no percentage of employees who participated in regular performance and career development reviews is disclosed.

Method (page 269): "Data on training hours is captured in the SAP SuccessFactors LMS (Learning Management System). When calculating the number of hours of training per employee, employees (CSRD scope) present on 31 December of the year are taken into account."

The underlying programmes are the compulsory "Job Musts" for employees taking up new positions, future-skills training "in areas such as generative artificial intelligence, data and sustainability" delivered through L'Oréal University, and personalised development plans set under the CONNECT process on the ONE LEARNING platform (page 241). Participation in compulsory courses is tracked "using specific dashboards and e-mail reminders" (page 241).

Health and safety metrics

Reference: page 246 (sections 4.7.5.7.1 and 4.7.5.7.2).

Recordable accidents exclude "workdays lost owing to commutes and first aid accidents" (page 246).

Coverage is evidenced by "ISO 45001 certifications covering 94% of manufacturing facilities and the corpus of rules (EHS manual and all associated procedures)... ensur[ing] that 100% of employees are covered by the health and safety management system based on legal requirements and/or recognised standards or guidelines" (page 270).

Scope (page 269): monthly reporting by each entity into the GRAAL consolidated tool, covering "manufacturing facilities, internal distribution centres, research centres, administrative sites with more than 50 employees, and all stores and sales teams".

No number of days lost to injuries, accidents, fatalities or work-related ill health is published.

Compensation metrics (pay gap and total compensation)

Reference: page 246 (section 4.7.5.8).

"Given the high proportion of beauty advisors in the Group's workforce (almost 25%), two pay gap calculations are made... The beauty advisor population, which is predominantly represented by women (90%), has the lowest pay levels in the organisation. An adjusted pay gap calculation is also carried out to neutralise any structural variables... The adjusted pay gap comes out at 1.6%, more favourable to men" (page 246).

Annual total remuneration ratio of the highest paid individual to the median employee is published by Region rather than as a single Group figure (page 246): Europe 196 (2024: 179), Latin America 71, North America 45, North Asia 80, SAPMENA & SSA 82.

Method (page 270): annualised base salary at 31 December plus variable remuneration received in the year and long-term incentive plans awarded that year at fair value; one-off bonuses, shift premiums, car allocations and overtime are excluded, as are people on maternity, parental and long-term sick leave.

Incidents, complaints and severe human rights impacts

Reference: page 246 (section 4.7.5.9).

Reported discrimination incidents fell while Speak Up complaints rose.

Method (page 270): the Ethics, Risks and Internal Control Department owns these metrics and works with Legal and Compliance to identify fines and penalties. "Number of incidents/complaints: calculations are based on proven reports identified using established procedures (in particular the Speak Up whistleblowing platform)." Fines cover only amounts "levied by a judicial or administrative authority"; "Any damages awarded as part of individual settlements are not taken into account insofar as they are strictly confidential and relate to disputed allegations".

Severe human rights incidents cover working conditions, equal treatment and other work-related rights, "excluding cases already reported in the total number of incidents of discrimination reported, including harassment" (page 246).

Policies related to value chain workers

Reference: pages 251-252 (sections 4.9.2.1 and 4.9.2.2). "L'Oréal's Human Rights Policy, most recently updated in April 2025, underpins its ambition to see human rights respected throughout the value chain... The policy is based on the United Nations Guiding Principles on Business and Human Rights (UNGP) and the due diligence recommendations set out in the OECD Guidelines for Multinational Enterprises... and is built on four core pillars: identification of salient risks; culture of respect; stakeholder engagement; roll-out of transformation action plans" plus collaboration (page 251).

Governance: "The Chief Corporate Responsibility Officer, a member of the Executive Committee, is responsible for overseeing the respect of Human Rights and Fundamental Freedoms in the Group... A network of more than 50 human rights correspondents plays a key role in embedding this culture in every Group entity" (page 251).

The Sustainable Purchasing Policy and Mutual Ethical Commitment Letter set supplier requirements (page 252): prohibit child labour, the minimum age being the highest of the legal minimum, the age of compulsory education or 15; ban forced labour "within the meaning of the ILO indicators"; guarantee freedom of association; pay adequate wages; ensure occupational health and safety; guarantee access to water and sanitation; and combat violence and harassment.

Processes for engaging with value chain workers about impacts

Reference: page 253 (section 4.9.3).

Engagement runs mainly through suppliers and third parties rather than directly with workers.

"L'Oréal works closely with its direct suppliers to promote responsible social and environmental practices, particularly on matters surrounding human rights and adequate wages... Suppliers located in countries identified as high risk by Verisk Maplecroft are subject to a compulsory social audit before being listed as suppliers at L'Oréal. In early 2025, L'Oréal joined the Supplier Ethical Data Exchange (SEDEX) initiative, a global collaborative platform for managing and sharing ethical, social and environmental supply chain data... notably by relying on the Sedex Members Ethical Trade Audit (SMETA) methodology. SMETA... facilitates in-depth assessment of social risks such as forced labour and freedom of association" (page 253). "The Group also conducts human rights impact assessments in at-risk regions and sectors, as well as field projects."

The Human Rights Policy commits the Group to "working with L'Oréal's stakeholders, especially those directly affected, to resolve situations of risk or harm" (page 249).

1,499 social audits were conducted in 2025 (page 26).

Processes to remediate negative impacts and channels for value chain workers to raise concerns

Reference: page 253 (section 4.9.3).

"L'Oréal has set up channels for reporting potential human rights violations. These include dialogue with stakeholders, the Speak Up platform (a secure, anonymous website that can be accessed by all stakeholders, with a system on hand around the clock and available in 30 languages, and performance monitored via indicators) and the palm and wood fibre sector alert procedure that is available and communicated to all stakeholders, including workers in the value chain. The oversight process is designed to ensure strict confidentiality, fair treatment, protection against reprisals and compliance with national legislation in the countries where the Group operates" (page 253).

"If a violation of the human rights of workers in the value chain or affected communities is identified... The Group immediately engages in dialogue with its suppliers and implements a set of immediate measures aimed, if necessary, at identifying the precise source of the incident and rolling out action plans with the suppliers concerned" (page 253).

For systemic causes "the Group may call on a range of key players, from NGOs to public authorities, local civil society organisations and companies in the beauty and perfume industry" (page 253).

Taking action on material impacts on value chain workers

Reference: page 253 (section 4.9.3); social audit outcomes pages 187-188 (Vigilance Plan).

Five categories of measure apply (page 253): in-house training in responsible purchasing, compulsory for all onboarding buyers, with a human rights module that "informs buyers of the vulnerability of certain groups such as indigenous peoples"; supplier support and assessment, including compulsory social audits before listing for suppliers in countries rated high risk by Verisk Maplecroft; the Living Wage programme, developed with the ILO and the IDH Sustainable Trade Initiative, under which "Suppliers are encouraged to sign a pledge and to work towards an adequate wage for their employees"; contractual commitments through the Mutual Ethical Commitment Letter; and monitoring and complaints channels.

Collective action is also disclosed: "in response to a human rights risk identified in the rose sector in Turkey, L'Oréal joined the Harvesting the Future initiative launched by the Fair Labor Association, aimed at improving working conditions and respect for human rights in various agricultural sectors, focusing on empowering seasonal workers and their families", running to end-2026 with the Turkish government, local civil society organisations, processors and growers (page 253).

The Vigilance Plan reports 2,546 supplier non-compliance cases across 13 topics in 2025, of which 23 "Zero Tolerance" (page 187).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 254 (section 4.9.4.1).

The employment access target has been met five years early and exceeded; the living wage pledge target stands at a quarter of the way.

Both are defined at page 270. Strategic suppliers are "a list of strategic suppliers representing 80% of Direct Purchasing expenditure and 50% of Indirect Purchasing expenditure. Each year, a survey is sent to enquire whether they pay their employees a living wage, in line with expert recommendations (International Labour Organization and IDH Sustainable Trade Initiative). If this is not the case, the supplier may undertake to follow a time-bound action plan. The percentage published is based on these responses."

The employment target "is calculated as the sum of the difference between the number of beneficiaries of Inclusive Sourcing projects in the reporting year and the number of beneficiaries in 2020" plus "the number of graduates from the Beauty for a Better Life programme between 2020 and the reporting year".

Policies related to affected communities

Reference: page 251 (section 4.9.2.1), the same Human Rights Policy that governs value chain workers.

"In particular, L'Oréal recognises the rights of indigenous peoples, as defined by the United Nations Declaration on the Rights of Indigenous Peoples. The Mutual Ethical Commitment Letter commits L'Oréal and its suppliers to respecting human rights, including those of indigenous peoples. L'Oréal also supports local communities through projects on the ground related to its value chain" (page 251).

Two mechanisms are named (page 251): "compliance with the principles of the Nagoya Protocol on Access to Genetic Resources and the Fair and Equitable Sharing of Benefits Arising from their Utilization, in line with the Code of Ethics"; and "implementation of due diligence procedures on the ground (notably in line with the Group's Forest Policy) to identify and mitigate environmental and social risks (including for indigenous peoples). These include the dedicated palm and wood alert procedure and Speak Up".

The material sub-topic is the rights of indigenous peoples, the identified risk being "that the free, prior and informed consent of indigenous communities is not respected in the supply chain due to potential impacts of deforestation and use of land adjacent to these communities, such as for palm oil and palm oil derivatives" (page 250).

Processes for engaging with affected communities about impacts

Reference: page 253 (section 4.9.3), presented jointly with value chain workers.

Engagement with communities runs through the same supplier assessment and field programme machinery: "The Group also conducts human rights impact assessments in at-risk regions and sectors, as well as field projects" (page 253). Buyers receive compulsory training that "informs buyers of the vulnerability of certain groups such as indigenous peoples" (page 253).

Field engagement is described in the biodiversity chapter, where regenerative agriculture "is an approach to agricultural systems based on rehabilitation and conservation, and is developed in collaboration with local communities", including a palm plantation initiative in Indonesia run "partnering with local stakeholders and research centres like CIRAD" and aimed at raising "the incomes of local populations" (page 231).

The Human Rights Policy commits the Group to "stakeholder engagement: L'Oréal engages in active dialogue with its partners, takes their concerns into account and encourages them to set up transparent whistleblowing systems" (page 251).

Local communities are one of the eleven stakeholder groups in the SBM-2 dialogue table, with 2025 examples including Citizen Day, in which 28,700 employees across 73 countries volunteered for 680 non-profits (page 199).

Processes to remediate negative impacts and channels for affected communities to raise concerns

Reference: page 253 (section 4.9.3), presented jointly with value chain workers.

The channels open to affected communities are those open to value chain workers: "dialogue with stakeholders, the Speak Up platform (a secure, anonymous website that can be accessed by all stakeholders, with a system on hand around the clock and available in 30 languages, and performance monitored via indicators) and the palm and wood fibre sector alert procedure that is available and communicated to all stakeholders, including workers in the value chain" (page 253). A footnote adds that "Thanks to the procedure, supply chain grievances can be identified, assessed and monitored on an ongoing basis and, where necessary, a remedial action plan put in place" (page 253).

"If a violation of the human rights of workers in the value chain or affected communities is identified, the actions required depend on the specific context and are determined in light of an impact assessment and any information collected during discussions with stakeholders" (page 253).

The oversight process "is designed to ensure strict confidentiality, fair treatment, protection against reprisals and compliance with national legislation in the countries where the Group operates" (page 253). No count of grievances raised by communities is published.

Taking action on material impacts on affected communities

Reference: page 253 (section 4.9.3), presented jointly with value chain workers; page 254.

The measures at page 253 apply to communities as well as to value chain workers: buyer training on the vulnerability of indigenous peoples; supplier assessment and social audits; the Living Wage programme; contractual commitments through the Mutual Ethical Commitment Letter; monitoring and complaints channels including the palm and wood fibre alert procedure; and membership of coalitions such as the Consumer Goods Forum's Human Rights Coalition for Action.

Two named field actions bear directly on communities: the Harvesting the Future initiative in the Turkish rose sector, run with the Fair Labor Association, the Turkish government, local civil society organisations, processors and growers, "focusing on empowering seasonal workers and their families" and running to end-2026 (page 253); and the Indonesian palm plantation regenerative agriculture programme with CIRAD, aimed at raising "the incomes of local populations" (page 231).

Inclusive Sourcing targets "companies employing people from socio-economically disadvantaged communities: for example, people with disabilities, senior citizens, the long-term unemployed, women in vulnerable situations, refugees, asylum seekers", and companies "whose ownership and/or management is certified as being majority-owned by traditionally under-represented groups" (page 253).

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 254 (sections 4.9.4.1 and 4.9.4.2).

The community-facing targets sit in the "Supporting communities" pillar of L'Oréal for the Future:

The report is explicit that the last two are not DMA-driven: the Group "incorporates fundamental objectives which, although not directly linked to the results of the double materiality assessment in the strict sense of the CSRD, embody a deep conviction and the raison d'être of the Group" (page 254).

Method (pages 270-271): brand social engagement beneficiaries "are reported by each entity concerned using an internal tool, based on information certified by NGOs and Partners"; the number of women benefiting is "reported by the L'Oréal Fund for Women, based on certificates of authenticity from NGOs and Partners".

No target is set on the rights of indigenous peoples, the material S3 sub-topic (page 202).

Policies related to consumers and end-users

Reference: pages 247, 255, 257 and 258 (sections 4.8.2, 4.10.2, 4.11.2 and 4.12.2).

Four policies cover the four material S4 areas.Personal data protection (page 247): the Data Privacy at L'Oréal policy rests on six principles – a people-centric approach, trust with employees, ethics ("the Group uses personal data ethically, lawfully and responsibly, and does not collect sensitive information without the consent of the person concerned"), lasting trust, involving General Management, and managing risks. Governance runs through a Group Strategy Committee, Region Steering Committees ensuring compliance with the GDPR, CCPA, PIPL and LGPD, and country-level committees (page 248).

Quality and safety (page 255): meeting consumer expectations, complying with legal obligations and safety requirements, maintaining and reviewing assessment standards, and ensuring quality and conformity across the supply chain. The Worldwide Safety Evaluation Department "establishes the toxicological profile of ingredients... and finally verifies the tolerance of the formulas before they are marketed".

Labelling and responsible consumption (page 257): "encouraging responsible consumption by offering greater transparency" and "encouraging environmental product design". Responsible marketing and advertising (page 258): anchored by the Code of Ethics, Human Rights Policy, DEI policy and Influencer and Content Creator Values Charter.

Processes for engaging with consumers and end-users about impacts

Reference: page 249 (section 4.8.3); page 255 (section 4.10.2); page 257 (section 4.11.3).

Data privacy (page 249): "L'Oréal has set up a dedicated email address that consumers and employees can use to ask questions of Data Privacy Officers regarding the protection of their personal data."

Product safety (page 255): an international cosmeto-vigilance network "staffed by health experts at Group, R&I and science department levels in 100 or so countries... is an integrated surveillance system which collects, records, evaluates and processes spontaneous reports of adverse health events observed in relation to products on the market. Reports can be submitted by external stakeholders, particularly consumers and healthcare professionals and authorities." Consumer service teams are reachable "mainly by phone, social media or e-mail", with each brand's contact displayed on the products, and feedback is passed to brand managers through Voix du Consommateur reports.

Labelling (page 257): the EcoBeautyScore Association ran a public consultation in June 2024, and in 2025 its methodology and platform "were independently reviewed and verified by E&H, the consultancy arm of the Ecocert group".

Consumers are one of the SBM-2 stakeholder groups, engaged for the purpose of "Staying attentive to current and future needs and concerns, expectations and changing consumption patterns" (page 200).

Processes to remediate negative impacts and channels for consumers and end-users to raise concerns

Reference: page 255 (section 4.10.2); page 249 (section 4.8.3); page 260 (section 4.13.2.1).

"Every contact is treated with care: the consumer service team records the reason for the contact request and seeks to resolve the problem using a decision tree. The team is required to keep the consumer informed of the progress of their case... Requests to analyse certain products are forwarded to the quality coordinator and then to the internal unit concerned. The consumer systematically receives a response from the consumer service team summarising the exchange and the next steps" (page 255).

Remediation on safety runs through cosmeto-vigilance, which allows L'Oréal to "if necessary, propose appropriate corrective measures, such as improving tolerance through reformulation, removing or substituting certain ingredients", to "identify certain misuses" and to "improve labelling to ensure better use of products". "This market surveillance system also meets the regulatory requirements in force in certain countries through dialogue with the competent authorities" (page 255).

Speak Up is open to external stakeholders, available around the clock in 30 languages, with reports reaching the Chief Ethics, Risk and Internal Control Officer (page 260).

Taking action on material impacts on consumers and end-users

Reference: page 249 (4.8.3); page 256 (4.10.3); page 257 (4.11.3); pages 258-259 (4.12.3). Privacy (page 249): the 10 Key Points on Personal Data Protection charter and the GDPR-inspired Data Privacy at L'Oréal policy; a network of data protection professionals at Group, business, Region and Country level; supplier compliance requirements "supported by certifications and maturity assessments"; and internal audits "included in its annual audit plan submitted to General Management and the Audit Committee for approval".

Product safety (page 256): "All production facilities are ISO 9001 certified and apply ISO 22716 compliant Good Manufacturing Practices. These standards also apply to subcontractors under a specific quality charter."

Labelling (page 257): in 2025 the EcoBeautyScore methodology and platform were independently verified against the European Commission's Product Environmental Footprint methodology and ISO 14020/14025, and L'Oréal "initiated the digital deployment of EcoBeautyScore on the face care products of... L'Oréal Paris and Garnier, in France and Germany", with all published scores verified by an independent third party.

Marketing (pages 258-259): minimal retouching, claims "based on solid, verifiable data", exclusion of inappropriate advertising environments, influencer disclosure of commercial links, and no use of "AI-generated human-like models to promote product benefits".

Targets related to managing material negative impacts, advancing positive impacts, and managing material risks and opportunities

Reference: page 276 (section 4.15.3 content index); page 262 (methodological notes).

L'Oréal sets no quantitative target for consumers and end-users. Against S4-5 the ESRS content index carries, in place of a section reference, the statement "L'Oréal has not set a quantitative target for this topic" (page 276). It is the only disclosure requirement in the index answered that way.

The general rule in the methodological notes applies: "The absence of a quantified target in the 'Outcomes' part of a sub-section of this report indicates that L'Oréal does not define any such target for this topic. It reserves the right to do so at a later date" (page 262). Consistent with that, sections 4.8, 4.10, 4.11 and 4.12 – privacy, product safety, labelling and marketing – carry background, policies and action plans but no "Outcomes" subsection with targets or metrics.

The four material S4 areas are protection of consumer privacy, personal safety of consumers, access to quality information and responsible marketing practices (page 202). Progress is tracked qualitatively instead, for example on labelling: "In 2026, the Group intends to generalise EcoBeautyScore and incorporate new eligible product categories for the entire European market" (page 257).

Business conduct policies and corporate culture

Reference: page 260 (sections 4.13.2.1 and 4.13.2.2).

"L'Oréal's development and reputation are underpinned by the essential ethical principles of integrity, respect, courage and transparency. Its ethics policy relies on two main pillars" (page 260):

• The Code of Ethics, which "applies to all employees, members of the Executive Committee and Management Committees and the Group's Directors and corporate officers... Compliance with these principles is taken into account in the assessment of each employee's performance, particularly managers."
• Speak Up, introduced in 2008, which "can be used by employees and external stakeholders to report concerns or breaches of Group rules in complete confidence, particularly in the areas of human rights, safety, corruption and the environment", via a secure anonymous website available around the clock in 30 languages. "L'Oréal protects whistleblowers, ensures that information remains confidential, and undertakes to conduct an independent and impartial investigation into each report, followed by remediation if necessary."

The policy for responsible relationships with suppliers, formalised in The Way We Work With Our Suppliers (page 260), commits the Group to fair supplier selection on objective criteria, to "nurture a climate of trust and collaboration... prohibiting all forms of corruption or favouritism", and to pay all suppliers on time.

Management of relationships with suppliers

Reference: pages 260-261 (sections 4.13.2.2 and 4.13.3.2).

The policy, formalised in The Way We Work With Our Suppliers, commits L'Oréal to "select its suppliers rigorously and fairly, using open and transparent competitive bidding based on objective criteria for assessing areas such as quality, price, innovation and performance in terms of social and environmental responsibility"; to "nurture a climate of trust and collaboration... prohibiting all forms of corruption or favouritism"; and to "see that financial commitments are met by paying all suppliers on time" (page 260).

Suppliers sign the Mutual Ethical Commitment Letter, "which sets out requirements in terms of respect for human rights, decent working conditions, environmental protection and business integrity". Eligible suppliers "represent 100% of the value of purchases for the manufacture of finished products and 90% of... other types of purchases" (page 260).

Five action priorities follow (pages 260-261): transparent communication of the supplier guide with tools and training for buyers; ongoing dialogue; monitoring payment times through updated internal tools and "pay on time" indicators, with the Group striving "to find amicable solutions to any financial difficulties encountered by its suppliers"; audits and assessments by independent third parties; and support and progress. Management of relationships with suppliers is a material G1 sub-topic (page 259).

Targets related to business conduct

Back-filled from the business conduct chapter and the methodological notes, where targets are addressed as part of the MDR-T/GDR-T disclosures rather than as a numbered DR. G1-3 became a standalone DR only in the 2025/2026 ESRS.

L'Oréal discloses no measurable business conduct target. Section 4.13 carries a background, policies and action plans but no "Outcomes" subsection with targets, and the methodological notes state the general rule: "The absence of a quantified target in the 'Outcomes' part of a sub-section of this report indicates that L'Oréal does not define any such target for this topic. It reserves the right to do so at a later date" (page 262).

Consistent with MDR-T's other limb, effectiveness is tracked in the absence of targets (page 260):

• Raising awareness and training – compulsory online training for all employees on ethics, human rights, anti-corruption, competition law and data protection, targeting "around 60,000 people who are exposed to such risks", plus an annual Ethics Day.
• Encouraging the reporting of unethical behaviour through Speak Up, with protection from retaliation and impartial internal investigation.
• Auditing and ensuring compliance – "the internal audit system ensures compliance with laws, regulations and Group policies, identifying weaknesses and determining any remedial measures."

Payment performance is tracked through "pay on time" indicators (page 261).

Payment practices

Reference: page 261 (section 4.13.4).

Average payment time lengthened by one day, the share of payments made within standard terms improved by one point, and outstanding late-payment proceedings halved.

The supporting action is set out in the supplier relationship action plan: "monitoring payment times: to ensure that contractual payment terms are respected, L'Oréal has updated its internal tools and purchasing terms and conditions, while closely monitoring 'pay on time' payment performance indicators. The Group strives to find amicable solutions to any financial difficulties encountered by its suppliers" (page 261).

The underlying commitment in The Way We Work With Our Suppliers is to "see that financial commitments are met by paying all suppliers on time, regardless of the category of supplier and according to the agreed terms, pursuant to local legislation and the Group's contractual commitments" (page 260).